ML20214A127
| ML20214A127 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1986 |
| From: | Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20214A071 | List: |
| References | |
| REF-QA-99900100 NUDOCS 8611190239 | |
| Download: ML20214A127 (24) | |
Text
e ORGANIZATION: LIMITORQUE CORPORATION
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LYNCHBURG, VIRGINIA REPORT INSPECTION INSPECTION N0.: 99900100/86-01 CATES: 09/22-26/86 ON-SITE HOURS:
12 CORRESPONDENCE ADDRESS:
Limitorque Corporation ATTN: Mr. F. K. Denham Executive Vice President 5114 Woodall Road Lynchburg, Virginia 24502 ORGANIZATIONAL CONTACT: Mr. P. McQuillan, QA Administrator TELEPHONE NUMBER:
(804) 528-4400 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of motor and manual operated valve actuators.
ASSIGNED INSPECTOR: \\
[6\\A14%.L
/[-Y N Date T. Conway, Reagive Inspection Section (RIS)
OTHER INSPECTOR (S):
J. J. Jacobson, RIS
- 0. Gormley, Equipment Qualificatic o S. Alexander, E InspectionSection(EQIS) y T. Tinkle, Consultant Date E.W.Merschoff, Chip (fRIS,VendorProgramBranch IFSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B and 10 CFR Part 21.
B.
SCOPE:
This inspection was made as a result of the receipt of 10 CFR Part 21 reports from:
(1) Portland General Electric Company (PGEC) relating to defective motor insulation in H. K. Porter / Peerless motors, (2) Georgia Power Ccmpany (GPC) pertaining to damaged internal wiring in (continued on next page)
PLANT SITE APPLICABILITY: Defective motor insulation - Trojan (50-344);
Damaged internal! wiring - Vogtle 1 & 2 (50-424/425); Cracking of. limit switch rotors - Rancho Seco (50-312); and Unqualified terminal strips - Arkansas Nuclear 1 & 2 (50-313/368).
8611190239 861107 PDR GA999 EMVLMIT 99900100 PDR
f ORGANIZATION: LIMITOROUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 2 of 21 B.
SCOPE (continued):
Type SMB-000 operators, (3) Sacraaento Municipal Utility District (SMUD) on cracking of limit switch rotors, and (4) Arkansas Power & Light (AP&L) on unqualified terminal strips.
A.
VIOLATIONS:
1.
Contrary to Section 21.31 of 10 CFR Part 21, Limitorque did not pass on the requirements of 10 CFR Part 21 to WESCO (Puchase Order (PO)
No. 1825 dated April 18,1986) for Rockbestos wire and to Barker Jennings Corporation (P0 No. 3579 dated September 19, 1986) for calibration services.
(86-01-01) 2.
Contrary to Section 21.51(b) of 10 CFR Part 21, limitorque was unable to provide documented evidence that an adequate review and evaluation was performed for possible 10 CFR Part 21 reporting on Type SMB-000 motor operators containing wiring that can be potentially damaged by the energization of the installed space heaters as determined by the following (86-01-02):
a.
A GPC 10 CFR 50.55e report to the NRC dated March 20, 1986 described damaged (burnt) wiring on a number of safety-related Limitorque motor operators.
b.
An NRC inspector at Vogtle Nuclear Power Plant on May 20, 1986 observed burnt wiring on a number of Limitorque operators.
B.
NONCONFCRMANCES:
1.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection l-A.1 of Section I of the Quality Assurance Manual (OAM), and Section 5 l
of ANSI N45.2-1977, it was noted that Limitoroue failed to impose the requirements of a QA Program (ref. P0 Nc. 3M4515 dated January 2P, 1985) upon H. K. Porter for nine Class 1E CC motors which were used on safety-related operators sent to Portland General Electric Company (PGEC) for use at the Trojan facility.
(86-01-03) 2.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 6 of ANSI N45.2, written instructicts/ procedures did not exist for i
current practices followed by the (a) Parts Department to ensure correctness and completeness of spare part orders, and (b) Parts Department, Application Engineering, and Ouality Control to initiate, review, and issue Certificates of Compliance (CofC) for spare part orders.
(86-01-04)
f ORGANIZATION: LIMITORQUE CORPORATION
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LYNCHBURG, VIRGINIA REPORT INSPECTION N0 : 99900100/86-01 RESULTS:
PAGE 3 of 21 3.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 2 of ANSI N45.2, limitorque did not process AP&L Company P0 No. 51965 for terminal strips under controlled conditions to assure that prerequisites affecting quality of the order were identified and accomplished.
It was noted that Limitorque incorrectly advised AP&L personnel that Buchanan 724 terminal strips were a correct replacement for qualified Buchanan 524 terminal strips, and issued a CofC that certified that Buchanan 724 terminal strips were environmentally qualified in accordance with tests documented in Limitorque Report B0119, Revision 1, dated November 10, 1982.
As a result, AP&L was supplied with Buchanan 724 terminal strips that were, in fact, not cualified.
(86-01-05)
C.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Violation 85-01-01: 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.
Limitorque corrective action commitments made in a letter dated July 15, 1986, were reviewed. Limitorque has revised and reissued Procedure QCP-22 " Reporting of Defects for Safety-Related Equip-ment." The revised procedure clarifies and strengthens reporting requirements to comply with 10 CFR Part 21. The status of the technical issue cited under this violation was discussed with the QA Administrator. He stated that all instances where unqualified Baldor motors were used on safety-related P0s were identified prior to the November 1985 NRC inspection. Limitorque is not aware of any remaining required actions.
1 2.
(Closed) Violation 85-01-02: Limitorque was unable to provide documented evidence that required reviews and evaluatiuns were performed for four identified problems.
l l
The inspector reviewed Limitorque's corrective action commitments.
l The revised Procedure QCP-22 clarifies and establishes requirements for maintaining documentation to assure compliance with 10 CFR Part
- 21. The status of the four technical issues (motor pinion key failures, worm shaf t cear failures, H3BC actuator potential field maintenance problem, cracked / broken limit switch rotors) cited i
under this violation were reviewed with the QA Administrator. He stated that the status of these items has not changed since the November 1985 NRC inspection, and Limitorque is not aware of any i
remaining required actions.
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ORGANIZATION: LIMITORQUE CORPORATION LYNCHPURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 4 of 21 3.
(Closed) Violation 85-01-03: Limitorque did not post Section 206 and a " Notice" in the manufacturing area, and Procedure QCP-22 did not provide for notification of a deviation / defect in a basic component.
The inspector reviewed Limitorque's corrective action commitments.
The revised Procedure No. QCR-22 clarifies the procedure for evaluation of potential defects, notification of a Limitorque officer, and reporting of defects in safety-related equipment to the NRC. Section 206 and a " Notice" are now posted in the manu-facturing area as well as outside the lunch room in the office area.
4.
(Closed) Nonconformance 85-01-04: Thirteen 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 / manufacturers of components destined for actuators purchased by nuclear customers as safety-related items.
Limitorque said (ref. July 15, 1986 letter) that their P0s are consistent with the pertinent requirements of Section 5 of ANSI N45.2 in that they require vendors who are on the Approved Vendors List ( AVL) to supply material / components with certified material test reports (CMTR) and/or CofC.
In addition, the material /
components undergo receipt inspection.
The inspector reviewed CMTRs/CofCs and Receiving Inspection Reports l
for items supplied by the seven vendors noted above. The material /
components supplied by these vendors were not complex items, and each of the vendors was on the AVL.
5.
(0 pen) Nonconformance 85-01-05:
Limitorque did not update the QAM Revision 2, to address training of non OC personnel (e.g.,
j engineers, parts and shipping personnel, purchasing agents, order l
processors, and field service personnel).
l The inspector reviewed Limitorque's corrective action commitments.
i Section I of the revised QAM dated July 11, 1986 incorporated
" Indoctrination and Training of Non-0C Personnel Performing Activities That May Affect Quality." Training was applicable to personnel in the Engineering Departnent, Order Processing, Sales Group, Parts Department, Service Department, Purchasing Department, and Shipping Department.
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ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 5 of 21 In the July 15, 1986 response, Limitorque stated " Training of above personnel shall commence no later than September 17, 1986." A note dated September 17, 1986 from the OA Administrator to the OC Manager indicated that training for the non QC personnel had been rescheduled to commence on October 15, 1986. Since the training has not been completed, this item is considered open and will be reviewed during a future NRC inspection.
6.
(Closed) Nonconformance 85-01-06: Limitoraue's written practice, Procedure No. OCP-11, for nondestructive examination (NDE) did not describe the responsibility of each level of certification or rules covering the duration of interrupted service requiring re-examination and recertification, and the qualification records of three NDE personnel did not contain a statement indicating satisfactory completion of training in accordance with Procedure No. QCP-11.
The inspector reviewed Procedure No. OCP-11, " Nondestructive Testing Procedure," revision dated July 11, 1986. Section II-A.1 included rules covering the duration of interrupted service requiring re-examination and re-certification and described the respcnsibility of each level of certification. A review of the NDE records of four examiners indicated that each qualification record contained a statement indicating satisfactory completion of training in accordance with Procedure No. QCP-11.
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7.
(Closed) Nonconformance 85-01-07: The area of "QA Records" (i.e.,
Section XI of the QAM) was not on the internal audit checklist l
form No. QC0019 and was not audited in 1983 and 1984.
t l
The inspector noted that "Section 0" has now been identified on the cover page of the checklist form No. QC0019. Section 0 includes I
QAM Sections IX " Material Moverrent" and XI " Records-General and Quality Assurance", and QCP 21 " Nuclear Service Procedure". A review of the 1983 and 1984 Internal Audit of Manufacturing verified that Section 0 " Safety Related Units" had been audited by the QA Administrator.
8.
(Closed) Nonconformance 85-01-08: Limitorque failed to generate semi-annual Vendor Evaluation Reports (VER) for 11 vendors, 11 other vendors having icw ratings remained on the AVL, and audits were not performed on Page-Wilson Corporation and Hartzog Granite Company who calibrated the hardness testers and surface plates, respectively.
1
t ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 6 of 21 The inspector reviewed the AVL dated August 13', 1985 and approximately 25 VERS which documented the vendors (including the 11 sited above) performance from June to December 1985. With regards to the ut.her 11 vendors, one vendor was dropped from the AVL, and letters, which.
the inspector reviewed, were sent to the remaining 10 vendors notifying them of their deficiencies for subsequent corrective action to eliminate the minor nonconformances on future orders.
Procedurc No. QCP-25 revision dated September 23, 1986 documented the method for qualification of vendors (e.t., Page-Wilson and Hartzog Granite) who perform services at the Linitorque facility.
This procedure was reviewed, and it was also verified that a QC personnel had witnessed the calibration of equipment performed onsite by Honeywell on June 16, 1986.
9.
(0 pen) Nonconformance 85-01-09: Limitorque did not affectively implement QA program requirements for reporting 6efects in safety-
~
related equipment.
The inspector reviewed Limitorque's corrective actidn commitments.
Limitorque's revised and reissued Procedure QCP-22 became effective July 11, 1986. A memo dated August 6,1986 in the QC Manager training book stated that the Executive Vice-President, the Chief f Engineer, and the Technical Panager had teen indoctrinated in the.
usage of QCP-22. The current revision of Procedure QCP-22 establishes a Part 21 Review Committee and assigr,s the QA Administrator as the chairperson. The QA Administrator stated that no items have been submitted to the Part 21 Review Ccnriittee since this revision became effective, and the Connittee has not met as of the date of this inspection.
Since documentation does not exist upon which to evaluate the implementation effectiveness of QCP-22, this item is considered open and will be reviewed during a future NRC inspection.
10.
(Closed) Nonconformance 85-01-10: Limitorque could not provide uy documented evidence that measures were taken to identify the cause of a significant condition adverse to quality, the extent of the problem, and necessary corrective action to preclude repetition; or that the condition was reported to appropriate 11evels of management.
The inspector reviewed Limitoroue's corrective action commitments.
The revised and reissued Procedure QCP-22 clarifies and establishes requirements for maintaining documentation to assure compliance with 10 CFR Part 21. The status of the technical issue cited under this nonconformanct (use of unqualified Baldor motors) was
t,
=
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ORGANIZATI0': LIMITOROUE CORPORATION N
LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 7 of 21
, l discussed with the QA Administrator. He stated that all instances
. - - - 'I where unqualified Baldor motors were used on safety-related PCs weFe identified prior to the November 1985 NPC inspection.
. Limitorque is not aware of any remaining required actions.
D.
OTijERFINDINGSANDCOMMENTS:
1.
Unqualified Buchanan Terminal Strips s
Dased on information in a 10 CFR Part 21 report dated July 16, 1986, AP&L requested a quote for 15 Buchanan 524 terminal strips for Limitorque actuators while preparing for a refueling outage. The
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- Buchanan 524 terminal strips are environmentally qualified and made
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of a brown phenolic material. Limitorque stated that Buchanan 524 terminal strips were not available, but that Buchanan 724 terminal strips (Part No. EA3-0724-12) were available and were a correct replacement.
4 On June 18, 1986, Limitorque received P0 No. 51965 from AP&L.
Item 9 on the purchase order was for 15 Buchanan 724 terminal strips. The 4
P0 invoked 10 CFR Part 21 and requested QA documentation certifying
_ the Buchanaa 724 terminal strips to 10 CFR Part 50, Appendix B and ca
. ANSI N45.2 and that the Buchanan 724 terminal strips were the Jcorrect replacement and environmentally qualified per Limitorque
~_
l Test Report B0119 Revision 1.
(Note: Buchanan 524 terminal strips are environmentally qualified per Limitorque Test Report 80119 Revision 1.)
A P0 acknowledgement (Order No. 3T3534) was issued by Limitorque "an June 19, 19E6, in response to AP&L PO No. 51965, and a nuclear
/
safety-related application product identification code was assigned
.to this urder. On June 19, 1986 the Parts Department initiated a request (Form LP-450) to the CC Manager to issue a CofC for the Buchanan 724 terminal strips to certify:
Parts supplied are compatible and interchangeable with the a.
original equipment, b.
Parts described net the P0 requirements.
Parts supplied were provided in acccrdance with Limitorque's c.
QA Program dated January 4, 1984, which meets the applicable requirements of 10 CFR Part 50, Appendix B, and ANSI N45.2.
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/
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ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 8 of 21 d.
Parts supplied are qualified per IEEE 323 (1974), IEEE 382 (1972),andIEEE 344 (1975) for use inside/outside containment and are equal to or superior to those parts tested per Test Report'B0119, Revision 1, as contained in B0058 (culmination of all Limitorque Test Reports).
Proper installation of these parts will not adversely affect e.
existing qualification of; the actuator involved.
The Parts Department forwarded the request to issue the CofC to Application Engineering for review and approval. The Manager of Application Engineering approved the request on June 19, 1986. On July 3, 1986, the QC Manager issued a CofC that provided the requested quality docurrentation for the Buchanan 724 terminal strips.
Based on information in the AP&L 10 CFR Part 21 report of July 16, 1986, AP&L personnel, who were accustomed to seeing brown phenolic terminal strips, questioned the qualification status of the white 724 terminal strips following receipt of'the parts. The.Limi torque Parts Manager issued a Returned Goods Permit No.14985 on July 8, 1986, and the strips were returned to Limitorque and receipt inspected (Receiving Report R58144) en July 10, 1986.
A memo dated July 16,19E6, from the QA Administrator summarizes information concerning the cause and corrective mea,ures associated with the Buchar.an 724 terminal strips as follows: The AP&L P0 for the terminal strips was processed as an urgent delivery item. While processing the P0, limitorque personnel confirmed that Buchanan 724 and 524 terminal strips were identical in form, fit, and function.
However, they did not verify whether the Buchanan 724 terminal strips were environmentally qualified per Limitore,ue Test Report 80119, Revision 1.
As a corrective action measure, cognizant Limitorque personnel were notified by a memo dated July 14, 1986, that Buchanan 724 termir.al strips were not qualified. The unoualified Buchanan 724 terminal strips were returned to Limitorque. The QA Administrator l
believes the issuance of unqualified terrrinal strips to AP&L is ar.
i l
isolated case. A note dated September 17, 1986, indicated a computer printout had been generated to permit a search for other terminal PCs.
If an occurrence of a similar item is found, Limitorque will issue a separate 10 CFR Part 21 report.
Limitorque Test Report B0119, Revision 1, dated November 10, 1982, was reviewed.
Section 2.0 identifies the terminal strips (e.g.,
Marathon 300, Marathon 1600, Buchanan 0272, Buchanan 0524, General Electric EB-5, and Curtis Type "L") that were included in the i
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 9 of 21 environmental testing covered by the report. Limitorque P0 No.
40958 dated September 9, 1986, for Buchanan 724 terminal strips indicated that the terminal strips were purchased from an electrical supply house as a commercial catalog item. This was confirmed in a discussion with the QC Manager. The QA Administrator stated that Limitorque handled the 10 CFR Part 21 evaluation for the AP&L Buchanan 724 terminal strips in accordance with the version of Procedure QCP-22 " Reporting of Defects for Safety-Related Equipment" in effect prior to July 11, 1986.
(See Nonconformance 86-01-05.)
2.
Limitoroue Spare Parts Order Processing As a result of unqualified Buchanan 724 terminal strips being supplied to AP&L, an inspection of Limitcrque's procedures and practices associated with spare parts processing was performed. The inspection included a review of QAM and QC procedures related to spare parts orders. Actual practices associated with spare parts order processing were discussed with the Manager of Order Entry, the Parts Department Manager, and the QC Manager.Section IV of the QAM and Procedure QCP-16 " Order Entry and Processing Procedure" contain the Limitorque practices for order entry, processing, and specification review.
According to the Manager of Order Entry, QCP-16 is applicable to all orders which are divided into either actuator (unit) orders or spare parts orders. All orders go to the Manager of Order Entry who sorts the orders and routes all spare parts orders to the Spare Parts Manager. QCP-16 states the Manager of Order Entry or his designated appointee is responsible for ensuring the correctness and completeness of customer orders.
In practice, the Spare Parts Manager is the designed appointee of the Manager of Order Entry for spare parts orders.
l The following Spare Parts Department practices, which are not currently covered by written procedures, were identified during conversations with the Parts Department Manager:
Any individual in the Parts Department designated by the a.
l Parts Department Manager can initiate and review an order acknowledgement for a customer spare parts order.
b.
The Spare Parts Department initiates requests to the QC Department to issue quality documentation requested by customer spare parts orders. These requests are made en a standard form (LP-450). Only the Parts Department Manager or his designated alternate (currently one individual) can l
initiate these requests.
The Parts Department can make a
ORGANIZATION:
LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 10 of 21 direct request for the QC Manager to issue CofCs if the certification is for parts that are (1) equal to or better than the original, (2) compatible and interchangeable with the original, (3) in accordance with the customer's own form, (4) in accordance with the customer's P0, or (5) in accordance with the Limitoroue QA Program which includes certifying to 10 CFR 50, Appendix B and ANSI M45.2.
If the customer P0 requests a CofC indicating qualification to a specific test report or certification to some other quality specification, the Parts Department sends the LP-45D form to Applications Engineering for review and approval prior to submittal to the QC Manager.
The Parts Department uses parts numbers to determine the c.
correctness and completeness for a customer order. A spare with a part number identical to that supplied on the original order is considered to be the correct spare part for current orders.
Section II of the QAM discusses product design, standards, and engineering document control.Section II.B discusses the function of the Applications Engineering Group as a consulting body for the
" Sales Engineering Force" and checkers for the QA Department. A note in this section states the following:
Order Entry and Processing are a ccmplete and separate entity and have the primary responsibility for the selection of the correct Limitorque " Standard" for the equipment sold (see Order Entry and Processing Procedure).
Order Entry and Processing personnel are not permitted to render any judgement or apply any Limitorque " Standard" unless it is strictly within the Engineering Oualification Data without the written approval of the Application Engineering Department.
Procedure QCP-21 " Safety-Related Nuclear Service Procedure" identifies requirements for processing orders for safety-related nuclear service. Some of the requirements in QCP-21 are not specific as to whether they apply to spare parts orders as well as actuator orders. This point was discussed with the QC Manager who indicated he was aware of this concern. The QC Manager further I
provided a draft revision to QCP-21 that will include some specific requirements applicable to spare parts orders for safety-related nuclear service.
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 11 of 21 Curing conversations with various Limitorque personnel, the inspector observed that some confusion exists within Limitorque concerning which requirements in the QAM, QCP-16, and QCP-21 apply to spare parts orders. The confusion arises from requirements that simply refer to " order" and are not specific as to actuator orders or spare parts orders. Some departments consider that certain of these requirements apply both to actuator and spare parts orders while other departments consider that these requirements apply only to actuator orders. The interpretation for a particular requirement is not necessarily consistent among the departments involved. This matter was discussed with the Manager of Order Entry, the Spare Parts Manager, and the QC Manager.
(See Nonconformance 86-01-04.)
3.
Valve Actuator Weight Discrepancies Babcock & Wilcox (B&W) was notified in December 1984 of discrepancies in valve actuator weights listed in the valve vendor drawings for seismic analysis. This problem, which involved valves manufactured by Anchor / Darling, Rockwell International, Copes-Vulcan, and ACF industries was identified by TVA at Bellefonte Units Nos.1 and 2.
This item was discussed during the November 1985 NRC inspection of Limitorque and left as an open item.
On July 18, 1986, NRC headquarters was advised that a weight discrep-anCy Was identified with a Limitorque actuator supplied to the Palisades nuclear plant. The actuator in question was a rebuilt SMB-00 that was found to weigh 260 pounds. Consumers Power stated the actuator weight on the valve vendor drawing is 168 pounds.
Limitorque's Technical Manager stated that Consumers Power contacted him and advised of the actuator weight discrepancy. He advised that the weight of SMB-00 actuators varies depending on various factors such as motor size and actuator application and that the 168 pound figure seemed low. The Technical Manager stated that Limitorque was unable to provide any additional information on the specific actuator until the serial number or order number for the actuator was identi-i fied by Consumers Power.
1 In an attempt to obtain general information on typical weights of SMB-00 actuators, limitorque provided two documents for review:
a.
A report dated February 25, 1985, with results of calculations performed for B&W (P0 048072LU, limitorque Order 3M5776). A summary of data in the report for two sizes of SMB-00 actuators having four limit switches, motors (1000 RPM) with no brakes, i
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ORGANIZATION:
LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 12 of 21 and a handwheel size of 12 in. is presented below. Anchor Darling manufactured the valve on Order No. 3A6119 and the rest were manufactured by Rockwell.
Motor Total Order No.
(Ft-lb)
Enclosure Weight (lbs) 384231 10 Nucl.
290 384673 25 Water-210 proof 3A3659 25 Water-285 proof 3A6119 10 Nucl.
295 3A3658 10 Water-275 proof b.
Limitorque Date Sheet (Form SEL-16 dated October 17,1977) titled " Approximate Weights *." A summary of data for three sizes of SMB-00 actuators is presented below.
Motor (ft-lb)
Wei ght*
10 185 15 190 25 200
- CAUTION - Unit weights in this chart are approximate for standard units with standard motor (1800 RPM). Addition of optional equipment can increase standard weight considerably (i.e., add 40 pounds for side mounted handwheel, and 80 pounds for integral cover (min-max 30 pounds)).
In an attempt to gain a more complete understanding of the actuator weight discrepancy item, the inspector considers that the valve vendor drawings for the particular Palisades SMB-00 actuator should be reviewed as well as the technical basis for the information on the drawing.
1 ORGANIZATION:
LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA RE' ORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 13 of 21 4.
Cracked Limit Switch Rotors The inspector discussed with various personnel the 10 CFR Part 21 report dated June 10, 1986 from SMUD concerning cracks in limit switch rotors. This problem was previously identified in 1984 (ref.
Limitorque letter dated February 15, 1984 to Westinghouse). The cracks have been found only on manufactured white melamine rotors which were discontinued for use by Limitorque after 1979. Most of the cracks reported have been hairline in nature and pose no real safety significance.
Rotors currently used by Limitorque are made of a brown fibrite material which has been found to be more suitable for this application. Limitorque has suggested replacing any cracked white melamine rotors with the newer design brown fibrite rotors.
NRC Information Notice 86-71 dated August 19, 1986 addresses this problem.
5.
H. K. Porter / Peerless Motors In two 10 CFR Part 21 reports dated May 6 and June 6,1986, the NRC was informed by PGEC of a defect discovered in the motor lead insulation in replacement motor actuators for auxiliary feedwater flow control valves installed at the Trojan facility. The defect involved cracking of the motor lead insulation causing an insulation breakdown between the motor lead conductors and the grounded operator case. A short circuit developed which blew the power supply fuse to the operator rendering the associated valve inoperable.
Limitorque was advised of this problem and has determined that potentially defective motor lead ir,sulation was installed on DC motors manufactured by H. K. Porter / Peerless between the dates of i
November 30, 198a and December 6, 1985. During this time period, Peerless changed the motor lead insulation from a Nomex insulation with a glass braid epoxy impregnated overcoat to a Nomex insulation with a Kapton jacket. This change was approved by Limitorque based upon Peerless recommendations.
Peerless has since gone to a Nomex insulation with a non-epoxy impregnated glass braid overcoat.
Limitorque has determined this insulation system to be acceptable.
l Limitorque is currently determining those plants which Limitorcue nay have received operators containing the potentially defective notors.
Limitorque has agreed to inform the NRC in writing of proposed corrective action and a list of all affected plants within 30 days of this inspection.
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ORGANIZATION: LIMITORQUE CORPORATICN LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 14 of 21 The motors in question were contained in Model SMB-000 operators purchased from Limitorque on PGEC P0 No. N-29175 dated February 27, 1985.
PGEC's P0 required the operators to be manufactured in accordance with a OA program meeting the requirements of 10 CFR Part 50, Appendix B, and it also imposed the requirements of 10 CFR Part 21 upon Limitorque. Limitorque purchased the motors from H. K. Porter / Peerless under Limitorque P0 No. 3M4515 which invoked Limitorque specification E00-1 Rev. F and Limitorque Drawing No.
21-497-0014-1, Rev. B dated January 23, 1981. These documents contained specific performance characteristics for the motors; however, QA requirements were not imposed on H. K. Porter / Peerless (See Nonconformance 86-01-03).
Item No. 10 of Drawing No. 21-497-0014-1 passed on the requirements of 10 CFR Part 21 to the motor manufacturer. Limitorque revised Drawing No. 21-497-0014-1 to include QA requirements and motor lead insulation requirements in 1985 and 1986, respectively. Revision C dated July 10, 1985 to the Drawing added Item No. 11 which stated
" Motors to be supplied in accordance with the H. K. Porter Company's Quality Control Procedure Plant 1 dated April 14, 1982." Item No.
12, which stated, " Lead insulation shall be epoxy impregnated glass braid overcoat over nomex primary insulation" was added in Revision D dated June 15, 1986.
6.
Space Heaters In a March 20,198610 CFR 50.55e report, GPC notified the NRC of a problem concerning burn damage to internal wiring caused by energized space heaters in type SMB-000 Limitorque operators. The wiring was burnt due to its close proximity to or contact with the limit switch compartment space heaters or space heater brackets.
The wiring was not properly routed and was not restrained from contacting the heater or its bracket.
On May 20, 1986 an NPC inspectors along with Limitorque, GPC, and Bechtel personnel performed a random inspection on four type SMB-000 operators installed in Vogtle Unit 2.
Three of the four operators were found to contain burnt wiring. The wiring in question was installed by Limitorque and was forced into a small area in the limit switch compartment around the space heater bracket. The wire lengths were excessive making it difficult to fit all the wire into the small t
l compartment.
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a ORGANIZATION: LIMITORQUE CORPORATION
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LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 15 of 21 Limitorque's QA Administrator, who witnessed the inspection at Vogtle, indicated that the problem observed at Vogtle was caused by mishandling in the field and could not have possibly been caused by improper wire routing at Limitorque. GPC personnel disagreed with this observation.
On August 19, 1986, the NRC issued Information Notice 86-71 alerting licensees to this potential problem.
The NRC inspector reviewed applicable inspection procedures and wiring drawings at Limitorque and noted that documentation addressing the need to keep wiring away from space heaters or space heater brackets did not exist. The Limitorque Wiring Supervisor indicated that the space heaters used in the operators in question were made of a special chromolox type material which necessitated the use of a special bracket which created a problem due to the bulkiness of the heater bracket resulting in limited space for wire routing.
Restraints were not installed at Linitorque to keep the wiring away.
from the brackets. After viewing pictures of the wiring at Vogtle, the supervisor indicated that the wire routing appeared to be normal except for the fact that the wires were burnt and were in contact with the heater brackets. Limitorque has stated in internal documents that Quality Control Procedure 5 will be revised by December 31, 1986 to include instructions to keep wiring away from heaters and heater brackets.
During the inspection, the CA Administrator stated a 10 CFR Part 21 evaluation was not required because the problem was caused by mis-handling in the field. According to Procedure No. OCP-22 " Reporting Defects for Safety Reloted Equipment-Reference 10 CFR 21" the QA Administrator should have forwarded this problem to the Design Review Committee to permit a full evaluation. This problem constitutes a defect in a basic component, and an adequate evaluation should have been made to assess possible 10 CFR Part 21 reporting.
(see Violation 86-01-02) 7.
Blocking Valve Actuators f
During the NRC inspection in November 1985, limitorque was requested l
and was unable to provide Order File fo. 3H8897 which contained information pertaining to the blocking valve actuator involved in l
the " Salem Unit 2 Depressurization Event" discussed in NRC Vemo AE00/E509 dated July 25, 1985.
Limitorque was subsequently able e
to locate and provide the file which contained a bill of materials for the original blocking valve actuators as well as one for the replacement torque switches installed in the actuators at the time of the event.
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1 ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 16 of 21 The torque switches in question were factory set to actuate at 86 ft-lbs, which corresponds to a setting of 1 on the original torque switches and a setting of 13/4 on the replacement switches. Specific torque-turn curves are developed at Limitorque for each specific type of torque switch, and these curves must be utilized to properly set the switches. Limitorque noted that licensees should not set new torque switches to old torque switch settings, as settings sometimes vary between original and replacement torque switches as noted by the torque-turn curves.
8.
Control cf Purchased Vaterial and Services The inspector reviewed the overall controls that Limitorque imposes upon vendors supplying raterial and services to assure that applicable specification and QA program requirements were included or referenced in procurement documents, material and services were purchased from qualified vendors, and items meet the technical and quality require-ments identified in the P0s.
P0s and Receipt Inspection Reports (RIR), if applicable, for six vendors of items utilized in a nuclear actuator and one service vendor were reviewed. For all 13 PCs, it was noted that QA/QC personnel did not review any of the P0s as evidenced by no documented concurrence.
P0 ho. 3579 dated September 19, 1986 to Barker Jennings for calibratier.
of a set of Brown & Sharp gage blocks specified MIL-STD-45662 and traceability to the National Bureau of Standard that did not specify the requirements of 10 CFR Part 21. WESCO supplied Rockbestcs cable under P0 No. 1825 dated April 18, 1986. The P0 specified the require-ments of IEEE 383 and the Rockbestos Quality Manual-Nuclear Safety Related Products but did not document 10 CFR Part 21 requirements (See Violation 86-01-01). A September 17, 1986 memo from the QC Panager to Receiving Inspection documented six activities (e.g.,
verify wire meets P0 requirements, verify that CofC has been i
l reviewed, etc.) to be accomplished prior to releasing Rockhestos wire from the inspection station.
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Terminal blocks are ordered from a supplier (e.g., P0 No. 40958 l
dateo September 9,1986 to Foster Electric) to a Buchanan or l
Marathon catalog number. Receipt inspection only involves verificatior that the part no. on the box agrees with the part no. on the P0.
i Gear Limit Switches (GLS) consist of four rotors and a finger base.
Two P0s to Harvey Hubbell for GLS specified Part 21 requirements and
a ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 17 of 21 required a material certification. Rotors and finger bases were ordered on two separate P0s from Harvey Hubbell. As noted in RIRs, on a sampling basis both items were visually and dimensionally inspected.
P0 Nos. 21287 (August 15, 1986) and 21449 (September 15, 1986) were to Reliance Electric for AC motors. Both P0sspecified that the motors were to be in accordance with Limitorque specification EQC-10 and Drawing No. 21-497-0001, Revision H.
The drawing documented 14 specific items.
Item No. 13 which addressed the requirements of 10 CFR Part 21 was added in Revision F dated November 16, 1978.
Revision H dated July 9,1985 added Item No.14 which stated, " Motors to be supplied in accordance with Reliance Electric Company Quality Assurance Program, Rotating Machinery Group dated September 1984."
Receipt inspection is not performed on AC motors.
Two P0s(Nos. 21372 dated August 29, 1986 and 21429 dated September 15, 1986) were to H. K. Porter for DC motors.
Both P0sspecified
... Routine MTR Test, CofC, Viton Seals and 0-rings, submersible motors... built in accordance with H. K. Porter QC Procedure Plant I dated April 14, 1982 and Limitorque specification EQC-1 and Drawing No. 21-497-0014-1, Revision C...CofC required." Receipt inspection is not performed on DC motors.
Shaw Plastics supplied torque switch terminal blocks on two P0s. The P0sspecified Fibrite FM-5064 and a Limitorque drawing along with Part 21 requirements and requested a material certification. On a sample basis, a visual and dimensional inspection was performed on these terminal blocks.
It was noted that Limitorque had approximately 12 CA manuals from vendors on file. The Reliance Electric "Guality Assurance Manual" -
Rotating Machinery Group, revised September 1984 was the only controlled copy. There was no documentation available to show that any of the manuals were reviewed and approved by Limitoroue. The l
remaining manuals included:
i k'ebber QCM-1B, "QC Manual" dated October 21, 1983 H. K. Porter " Quality Control Procedures" Plant 1 dated April 12, 1982 l
Force " Quality Control Manual" dated July 21, 1986 John Fluke " Quality Assurance Manual" dated July 1979 l
American Spring & Wire Specialty "CC Manual" dated January 26, 1984 Crofoot Gear "QC Manual" (no date)
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ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 18 of 21 General Electric - Apparatus Service Division "QA Program" dated July 28, 1983 Ryerson Steel "Cuality Control Program" dated February 1980 Walker Machine & Foundry "QC Manual" dated 1982 Southern Centrifugal "QC Manual" dated May 10, 1985 Rockbestos " Quality Manual-Nuclear Safety Related Products" dated September 1982 Vendors are placed on the AVL if the vendor possess the capability to satisfy the requirements of the P0, the quality of the material /
item supplied meets the specific requirements of the P0, and they have an acceptable QA/QC program. Limitorque sends Vendor Appraisal Forms (VAC) to a prospective supplier / manufacturer, and the vendor fills in the two page questionnaire and returns it to Limitorque.
The NRC inspector reviewed approximately 20 VACs from vendors supplying items such as die castings, gears, springs, wire, and custom molded plastics.
A review of external audits indicated that eight audits were pre-viewed from 1985 to the present. The CC Manager indicated that the eight audits presented approximately 70% of the total of external audits performed by Limitorque. Webber Gage Division (calibrates the linear gage blocks) was audited in April 1985. The QC Manager audited Force, Inc. (electrical wire) in September 1986 with a 'new checklist' which incorporates 13 criteria from Appendix B and is a significant improvement over the old check list.
Peerless /Winsmith (DC motors) was audited in March 1985. Three different locations of Reliance Electric (AC motors) were audited in December 1983 and February and March 1984.
Fluke Manufacturing (Fluke motors) was audited in April 1985. An internal memo indicated that General Electric-Apparatus Service Division was audited May 31, 1985, but there was no evidence of a checklist or an audit report.
Approximately 14 RIRs and Limitorque drawings for 19 vendors were reviewed at the receipt inspection station to assure that specific characteristics cf items were being inspected. The receipt inspector uses the dimensions on the Limitorque drawing to determine the number of checks to be made of an item. The visual and dirrensional inspection is based on a sampling basis per MIL-STD-105. The vendors having RIRs ir.cluded Advance Pressure Casting (gear limit drive cartridge), Belgium Tool & Cie (machine drive sleeve), Crofect Gear (miter gear), Harvey Hubbell (gear limit switch rotor), American
i ORGANIZATION: LIMITOROUE CORPORATION
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LYNCPBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 19 of 21 Spring and Wire Specialty (torsion spring), Marion-Heil Bronze (motor clutch gear bushing), Maryland Precision Spring (clutch compression spring), Newcomb Spring (tripper spring), Alling-Lauder (spur gear), Schnorr (belleville spring), WESCO (wire), and Foster (wire). A " receipt inspection stamp" is used in place of a RIR for castings (Souther Centrifugal and Lynchburg Foundry) and steel products (Ryerson and Copperweld Steel).
Limitorque uses a VER on a semi-annual basis to maintain or leave a vendor on the AVL. Based on a review of 15 VERS for 11 vendors whose rating was below limitorque's quality standard and the vendor still remained on the AVL, it appears the QA program does not take into account the rating of a nonconformance to be a major or minor defect as sufficient reason to remove or leave a vendor on the AVL.
9.
Equipment Oualification (EO) Items The inspector reviewed supporting data and obtained additional information on the EQ status of relevant features of Limitorque operators. The features addressed were grease relief valves, "T" drains, mcunting orientation and grease / lubrication require-ments.
Other topics included qualification by similarity analysis, tests on degradable parts, cuality/ maintenance of E0 status on manufactured parts, and control of parts and services.
Testing by Limitorque to support ouclification of operators inside containment without grease relief valves was not conducted. All operators tested had grease relief valves. The test manager recalled seeing grease stains on the outside of operators after the tests which indicated that the relief valve had operated.
In addition, in test project F600 376A (Report F-C 3441) grease from the operator plugged the test chamber drain. This was interpreted as an indication cf a significant discharge of grease from the relief valve.
Two tests were run on operators 'for outside containment applications without grease relief valves. While no deleterious effects were observed in these tests, they did not duplicate the Design Basis Event (DBE) temperature / pressure excursions which are postulated to occur inside containment.
All inside containment tests on RH class motors used "T" drains.
One was used on the lowest part of each of two end bells of the Reliance motors, and the other ports were plugged. The Porter /
0RGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/86-01 RESULTS:
PAGE 20 of 21 Peerless motors were equipped with a single "T" drain in the only drain port which was oriented to be at the low part of the motor. The class B motors tested for outside containment as well as the high temperature class B RAD H Reliance motors tested in 1969 were not equipped with "T" drains. The current replacement is the class RH motors which do require the "T" drains to conform to the tested configuration. While the temperatures and pressures listed in Project Report 600198 are higher than those expected outside containment they are lower than those used for testing of motors for inside containment.
With regards to orientation, all operators were tested with the limit switch mounted vertically upward and the motor horizontal. Limitorque feels that other orientations are satisfactory but recommends avoiding an orientation which puts the gear case above the motor or limit switch to prevent problems resulting from lubrication accumulation in these electrical components. However, limitorque feels that undesirable orientations can be tolerated if an enhanced surveillance /
maintenance program is implemented to check for and correct any seal leakage. The recommendations concerning "T" drains in the lowest motor end bells continue to apply in off-rormal orientations.
Limitorque currently supplies operators with Exxon Nebula EP0 in the main gear box and Beacon 325 in the geared limit switch. Mobil 28 is reconinended for the limit switch gears for ambient temperatures above 150 F and is considered an acceptable substitute for the Beacon 325.
It is substituted either for convenience during manufacturing or in response to customer specifications. All the cualification tests were run with Nebula EP0 or EP1 in the main gear box, and the instruction and maintenance manual (Bulletin SMB-1-82C) notes that these are the only lubricants approved for nuclear use inside containment.
While deviations from test conditions can usually be supported logically, the analyses are conclusions of the manager of the project group which performed the tests. There are no documented analyses of the effects of the deviations. Limitorque believes that the decision on whether or not an operator is acceptable for use in a nuclear plant is the responsibility of the licensee.
l Motor and motor lead insulation, limit switch and torque switch nonmetallic parts, terminal strips, lubricants and gaskets have all been addressed in test reports and other documents. The
9 ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/86-01 RESULTS:
PAGE 21 of 21 only other degradable parts are 0-ring and quad ring seals.
Limitorque's position is that these rings are maintenance items and aging should not be a consideration. The tests did subject the 0-rings and quad rings to DBE temperatures and pressures, and the Viton 0-ring and quad rings received thermal aging and radiation in test No. B0212. Since all tests run for inside containment applications were run with "T" drains and it was established that the "T" drains and cable ways allowed the test environment to infiltrate the motor and limit switch compartment, maintaining the integrity of the seals and gaskets was not a concern except to exclude grease from electrical components. Limitorque feels that sufficient grease will stay in place after seal failure such that a significant number of actuator operations can be accomplished without gear or bearing failure.
E.
PERSONNEL CONTACTED:
P. McCuillan* - CA Administrator W. Miluszusky* - QC Manager R. del Campo - Part Department Manager D. Martin - Manager of Order Entry D. Williams - Parts Department D. Warsing - Technical Manager F. Denham* - Executive Vice President D. Eperson - Wiring Supervisor D. Pillow - Inspector J. Puryear - Inspector
- Attended Exit Meeting.
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