ML20236J548
| ML20236J548 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1987 |
| From: | Naidu K, Stone J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236J454 | List: |
| References | |
| REF-QA-99901091 99901091-87-01, 99901091-87-1, NUDOCS 8708060203 | |
| Download: ML20236J548 (9) | |
Text
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ORGANIZATION: FRANK ELECTRIC CORPORATION YORK, PEtiksYLVANIA I
)
REFORT INSPECTION
' INSPECTION l
h0.: 99901091/87-01 DATES: 04/20-23/67 ON-SITE H0tfPS-99
^
CORRESPONDENCE ADDRESS: Frank Electric Corporation ATTN: Mr. L. A. Shinneman President RD 5, P. O. Box 09 Willow Springs Lane York, Pennsylvania 17405 ORGANIZATIONAL CON 1ACT:
P. Lynch c
TELEPHONE NUMBER:
(7171 764-5959 NUCLEAR INDUSTRY ACTIVITY: Electrical panels for various applications.
I f[24[y ASSIGNED IhSPECTOR:
f t,-
h K.'R. haidu, Program Development and Reactive Date Inspection Section (PDRIS)
OTHERINSPECTOR(S):
[
APPROVED BY:
Py J. F. Storie, Chief, PDhlS, Venoor Inspection Branch ate INSFECTI0h BASES AND SCOPE:
A.
BASES:
10 CFR Part 21, Appendix B to 10 CFR 50.
B.
SCOPE: Review the implementation of the quality assuarance program in selected areas during the manufacturer of par.els for Duane Arnold j
and Limerick ar.d review records pertaining to panels furnished.
PLANT SITE APPLICABILITY: Duane Arnold (50-331), Limerick (50-353).
4 870B060203 870709 PDR GA999 ENVFRELC 99901091 PDR L - _ ________-_
ORGANIZATION: FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA I
REPORT INSPECTION on - ooon1n41/A7.01 PFSULTS:
PAGE 2 of 9 A.
VIOLATIONS:
Section 21.21 of 10 CFR Part 21 states in part, "Each individual, corpora-tion, partnership or other entity subject to the regulations in this part shall adopt appropriate procedures to (1) provide for (1) evaluating deviations or (ii) informing the licensee or purchaser of the deviation c
to be evaluated unless the deviation has been corrected."
Section 16 af the Frank Electric Corporation QA Manual states that nonconformances will be reported as required by 10 CFR Part 21.
Contrary to the above, FEC did not develop a procedure to implement the above requirements.
(87-01-01)
B.
NONCONFORMANCES:
1.
Criterion IX of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating and nondestructive testing are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria and other special requirements."
Paragraph 5.10.1.3.(1) of the American Welding Society standard D1.1 (1982) requires that weld joints prepared to qualify a Weld Procedure Specification (WPS) should be examined by either radiographic or ultrasonic testing.
Contrary to the above, welds prepared to qualify WPS CP202 Revision 1 were not subjected to either radiographic or ultrasonic examina-tions; they were only bend tested.
(87-01-02) 2.
Criterion XVIII of Appendix B to 10 CFR 50 states, in part, "A system of planned and periodic audits shall be. carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."
Paragraph 19.1 of the FEC QA manual states in part "To verify the effectiveness of, and compliance to the internal QA program, the QA manager is responsible to coordinate an internal audit. This audit will be perfonned annually, assuming that tnere is a representative sample available."
ORGANIZATION: FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA REPORT INSPECTION un. oaonino1/n7_n1 RESULTS:
PAGE 3 of 9 Contrary to the abbve FEC has not performed an internal audit since 1983 even though panels were being manufactured from 1984 to 1987 for installation in nuclear power plants.
(87-01-03)
C.
UNRESOLVED ITEMS:
No unresolved items were identified during this inspection.
D.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Background Information FEC manufactures electrical panels to meet various technical specifications for installation in nuclear power plants. FEC supplied safety-related electrical panels to the following nuclear power plants during 1984-1987.
Quane Arnold Energy Center (DAEC) 5 Alternate Shutdown Panels (ASP) 6 Alternate Shutdown Fuse Panels (ASFP) 2 Anticipated Transient Without Scram Panels (ATWS)
Limerick Unit 2 4 Plant Monitoring System Panels (PMS)
South Texas Project 2 Relief Valve Indicator Panels Arkansas Nuclear awer Station 2 Relief Valve Indicator Panels On March 25, 1987, DAEC informed the NRC of a potential 10 CFR Part 21 defect pertaining to the ASPS manufactured by FEC, and installed at DAEC. Specifically, DAEC determined that welds in the ASPS installed in 1985 were not adequately qualified to the requirements of American Welding Society (AWS) standard D1.1.
l 1
l This inspection was performed to review the adequacy of the FEC l
quality assurance program implementation during the manufacture of the ASPS and other safety-related panels with specific emphasis on L
ORGANIZATION:
FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA REPORT INSPECTION Mn. 00001001/r,7 01 RFSlHTS-PAGF 4 nf Q welding. The inspection included a visit to Limerick Unit 2 to inspect the welds on the safety-related PMS panels.
2.
Review of DAEC Panels Records a.
Technical Specification (TS) 7884-E-134-NI, prepared by Bechtel d
Power Corporation, Ann Arbor Division, Michigan, specifies the technical requirements for various panels manufactured by FEC.
Based on this TS, DAEC issued Purchase Order (P0) 009560 dated October 18, 1983 for 5 ASPS, P0 28511 dated July 16, 1986 for 6 ASFPs and P0 29110 dated August 22, 1986 for 2 ATWS panels.
The Technical Specification required welding to conform to AWS DI.1, 1982, specified the components to be used in the panels and their locations and required Certificates of Conformances certifying that the components met the IEEE-323 and IEEE-344 requirements. On May 14, 1984, FEC sent the following procedures to Bechtel Ann Arbor for approval:
- 5229 Cleaniig and painting procedure
- CP-204 - Marking and cleaning procedure
- CP-H513 Storage requirements for control panels fQC-1001 - Welding inspection and repair procedure The above procedures were approved and returned.
b.
AWS D1.1-1982 requiresWeldProcedureSpecifications(WPS)to be qualified by either radiographic or ultrasonic examination of the welds performed to the WPS. WPS CP202 was developed in 1977 to weld 2 sections of 4-inch diameter schedule 40-pipe with 30 bevels. The Procedure Qualification Record (PQR) indicates that radiographic examination of the welds on December 1, 1977 indicated the welds were acceptable. Welders were qualified to WPS CP202 after the welds performed by them were subjected to guided bend tests and determined acceptable.
In 1981, when WPS CP202 was revised, one of the essential variables, the gas flow rate was reduced from 35 CFH to 20 CFH. AWS D1.1 requires requalification of the WPS when an essential variable is changed and includes a PQR. The PQR for WPS CP202 Revision 1 was incomplete because qualifying welds were subjected to guided bend tests only and not radiographic or ultrasonic examination.
FEC stated that specimen weld coupons will be prepared and sent to an independent laboratory for radiographic and guided bend test examinations and a I
u
ORGANIZATION:
FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA REPORT INSPECTION nn - coonin01/A7 n1 RESUlTS-pAGE 5 of 9 complete PQR will be prepared. One nonconformance was identified for performing welding with an inadequate PQR.
(87-01-02) c.
The following types of welds were utilized during the manufacture of the electrical panels for DAEC and are specified in Note 4 of FEC drawing D8-5883-3 Revision D.
d i
(1) Fillet welds on outside corners.
(2) 3/16" fillet welds, 1" long, 6" or less on centers to weld sheet steel to channels.
(3) 3/8" plug welds 6" or less to weld hinges to sheet steel.
(4) 3/16" fillet welds to weld channels to angle irons.
(5) 1/4" fillet welds to weld angle iron to angle iro1.
(6) 1/4" buttweld to weld channel base webb and /langes.
AWS D1.1 permits the use of WPS CP202 (with an adequate FQR) to perform all the above welds according tc paragraph 5,10.3.3.
This paragraph titled, " Piping ard Tubing Qualification,"
states; "A joint welding procedure specification for groove welding of pipe or tubing qualified in accordance with 5-10-1 shall also constitute procedure qualification for fillet welding plate, or tubing in the same position qualified."
d.
Two Supplier Deviation Disposition Requests (SDDR) were initiated relative to problems in welding. FEC initiated SDDR 87-004 dated February 27, 1987 stating that FEC did not have a qualified WPS and filler material to perform structural welding per AWS D1.1, specifically, buttwelds joining 2"x2"x1/4" angle irons at the bottom and top of two ASFPs.
It was proposed that DAEC supply a qualified welder, a qualified WPS and filler material to perform the reference welds. These welds are similar to the ones on the ASPS already shipped and installed at DAEC.
DAEC brought an approved WPS identified as P1-T and a qualified welder to FEC. FEC rented a Gas Tungsten Inert Gas Welding (TIG) machine for this purpose. An open-butt technique was used to weld two 2"x2"x1/4" angle irons at the bottom and top.
The welds were inspected to FEC procecure QC-1004 which was approved by Bechtel on March 10, 1987.
ORGANIZATION: FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA REPORT INSPECTION t'n. 000n1001/97.n1 R FSill TS -
PAGF 6 nf Q SDDR 87-005 dated March 4, 1987 permitted FEC to use AWS D1.3 in lieu of AWS D1.1 for welding criteria. To satisfy the requirements of AWS D1.3, FEC prepared and qualified two WPS to weld 10 gage sheet steel in two weld configurations. Weld coupons were bend tested and determined satisfactory.
FEC prepared an additional WPS to buttweld two 2"x2"x1/4" angle
(
irons. A backing plate was used. Weld coupons were sent to DAEC's independent testing laboratory for radiographic examina-tion, bend and tensile strengths. During the examination, when the backing plate was removed, lack of fusion was observed along the root. The weld was rejected without any further examinations. DAEC completed the weld by utilizing a qualified welder, a qualified WPS and equipment rented by FEC. The seismic qualification of the \\SPs already shipped were reanalyzed and modifications were reportedly made to the ASPS to meet the seismic qualifications.
3.
Review of Limerick Unit 2 Panels FEC manufactured 15 Plant Monitoring System (PMS) multiplexer panels of which 4 were safety-related for Limerick Unit 2.
The welds on the panels were inspected at Limerick Unit 2 and the quality assurance records pertaining to the panels were reviewed at FEC.
a.
P0 #8031-M-273-AC dated flarch 13, 1986, was issued by Bechtel San Francisco and referenced Material Requisition (MR) 8031-M-273. The MR specified the technical requirements including the following:
(1) The panels were required to be welded to the requirements of AWS D9-1.
(2) The types of cables for internal wiring and the types of terminal blocks to be used in the panels were specified.
(3) Four panels designated as 2CZ723 (Division 1) 2 DZ724 (Division II), 2AZ725 (Division III) and 2BZ726 (Division IV)weredesignatedas'Q' items. Two input harnesses were also designated 'Q' items.
10 CFR Part 21 was applicable to the 'Q' items.
I ORGANIZATION: FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA REPORT INSPECTION wn. coon 1no1/97 n1 RESULTS-PAGF 7 of 9 (4)
FEC was to provide a seismic analysis / test report for the 'Q' panels. SDDR #1 and Bechtel's letter to FEC dated October 2, 1986, Document 207407, stated that "FEC shall not provide additional analysis / test reports."
FEC stated that Bechtel engineering performed the seismic analysis on the panels, c
b.
The welds on the 4 panels and general workmanship were inspected at Limerick Unit 2 for the following attributes:
(1 Porosity (2
Size and location of welds (3
Weld spatter (4) Undercut (5) Minimum effective throat The inspectors observed excessive weld spatter and reinforcement on some welds in two panels. The corresponding weld inspection checklists identified this deficiency and documented that corrective action was taken to remove the excessive weld spatter.
c.
Review of the quality assurance documentation indicates the following:
(1) SDDR dated August 25, 1986 authorized FEC to ship the panels without the plug-in power cables.
(2) WPSs100 and 101 were used to weld the panels. The WPSs were qualified to groove weld 0.12 to 0.25" sheet metal in the overhead positions using butt and 55 double bevel joint preparations. Procedure qualification test welds were visually inspected and determined acceptable to meet paragraph 2.4 of AWS D1.9.
Use of the WPSs to weld in all positions is acceptable per paragraph 2.3.1.9 of AWS D1.9 which states; " Qualification in the overhead position shall qualify the procedure in all positions."
Paragraph 2.2.2 of AWS D1.9 states; " Typical joint designs and details of joints are given in Appendix A7, Part A of this specification. Qualification of a groove weld joint may be used as a qualification of a fillet weld joint but not vice versa." FEC drawings 08-5794-8 and -9 specify fillet welds and groove welds. Therefore the WPS is considered acceptable for the welds performed.
~
ORGANIZATION: FRANK ELECTRIC C0RPORATION YORK, PENNSYLVANIA REPORT INSPECTION En - 000nin01/A7 n1 RFSULTS-PAGF A of 9 (3) Welders who performed the welds were qualified to the WPS.
(4) The weld inspection checklist identified cosmetic weld spatter on two panels which was subsequently corrected.
(5) Certificates of Conformance were available for the electrical components installed in the cabinets.
4.
Review of :he FEC Quality Assurance Programs Review of the FEC quality assurance (QA) program in selected areas indicated the following:
a.
An up-to-date organization chart with names was not available due to recent changes in personnel.
In April 1987, the chairman of the board replaced the president and the QA manager resigned.
An acting QA manager has been appointed in the interim.
FEC stated that an up-to-date organization chart reflecting the personnel changes would be completed and incorporated in the QA manual, b.
Adequate procedural controls are effectively implemented in the area of design control through bills of material, wiring diagrams, panels, and structural design drawings reflecting the technical specification requirements. The technical specifications reviewed specified the components to be used and their location in the panels.
c.
Adequate procedural controls exist for the control of purchased components, commensurate with the size of the FEC organization.
FEC either purchases components from a source listed on their approved vendors list (AVL) or a source listed on the purchaser's AVL. Receipt inspections are performed for incoming material which includes verification of receipt of the certificates of conformances for the materials supplied.
d.
Control of special processes was determined to be inadequate and one nonconfonnance was identified relative to an incomplete PQR. During the exit interview, FEC committed to scrutinizing their records and to organize them to be retrievable and auditable.
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ORGANIZATION: FRANK ELECTRIC CORPORATION YORK, PENNSYLVANIA REPORT INSPECTION hin. ooonino1/n?.n1 pFStil TS -
PAGF 4 nf 9 i
e.
In the area of audits, FEC did not implement the commitments in Section 19 of the QA manual. Specifically, paragraph 19.1 1
of the FEC QA manual states that to verify the effectiveness of and compliance to the internal QA program, the QA manager is responsible to coordinate and perform an internal audit. The audit was to be performed assuming that a representative
(
sample was available. The inspector informed FEC personnel that panels for DAEC, Limerick, South Texas Project and Arkansas nuclear power station were manufactured during 1984-1987, which constituted a representative sample of work in process and therefore audits should have been performed. The inspector informed FEC personnel that failure to perform audits was an item of noncompliance contrary to Criterion XVIII of Appendix B to 10 CFR 50. Noncompliance 87-01-03 has been identified in this area.
E.
EXIT INTERVIEW:
The inspector met with individuals mentioned in Section F and discussed the scope and findings of the inspection.
F.
PERSONS CONTACTED:
L. A. Shinneman, President C. L. Bollinger, Plant Operations Manager P. E. Lynch, Acting QA Manager D. A. Murphy, Sales Mar.3ger
- J. E. Campbell, Chief Engineer i
3 enotes that the individual was not present at the exit meeting on April 23, 1987.