ML20246J063

Part 21 Rept Re Namco Refusal to Certify Design & Matls for Replacement Namco Limit Switches Supplied by Masoneilan. Initially Reported on 890825.Switches Put on QC Hold Until Final Disposition of Switches Determined

ML20246J063
Person / Time
Site:	Wolf Creek
Issue date:	08/29/1989
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	Martin R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
REF-PT21-89, REF-PT21-89-138-000 PT21-89-138, PT21-89-138-000, WM-89-0218, WM-89-218, NUDOCS 8909050027
Download: ML20246J063 (3)

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f_ b WipLF CREEK NUCLEAR OPERATING CORPORATION .

p C Bart D. Withers pr w.n.no August 29, i989 g WM 89-0218 i.

'U. S. Nuclear Regulatory Commission

' ATTN: Document Control Desk Mail Station F1-137 Washington, D.' C.,20555-

, _R. D. Martin, Regional Administrator i .U.:S. Nuclear Regulatory Commission Region'IV, 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

Docket No. 50-482: 10 CFR 21 Notification Concerning; Masonellan Certification of Replacement Electrical Parts

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Gentlemen This letter is b'eing submitted pursuant to 10 CFR 21.21(b)(2) as a follow-up to. a telephone call between K. R. Petersen, Wolf Creek Nuclear Operating

-Corporation (WCNOC) and D. M. Hunnicutt, NRC on August 25, 1989.

s WCNOC has determined that Masoneilan could not provide a basis for-certifying conformance to WCNOC purchase order requirements for certain spare / replacement electrical parts for nuclear service control; valves. As explained in the attached evaluation, this deviation is considered to be reportable as a defect pursuant to 10 CFR 21.

If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.

cz Very truly yours, i:

Bart D. Withers President and Chief Executive Officer BDW/jad Attachment cet B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a

~D. V. Pickett (NRC), w/a d

I P.O. Box 411/ Burlirgton, KS 66839 / Phone: (316) 364-8831 I

?l?%88U M8FDC % ~ ~ c~ ~~

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e Attachment to WM 89-0218 Page 1 of 2 10 CFR 21 Notification Concerning Masoneilan certification of Replacement Electrical Parts In 1988, Wolf Creek Nuclear Operating Corporation (WCNOC) attempted to procure spare NAMCO limit switches (model EA170-51100) from Masoneilan. When Masonellan placed the order with NAMCO for the model EA170-51100 switches, NAMCO refused to certify the switches as being similar in design and materials to the switch ordered in the construction of Wolf Creek Generating Station (WCGS). NAMCO informed Masonellan that NAMCO model EA170-51100 was not the correct model designation for the equipment being purchased and that the switch that was qualified was model EA170-51302. NAMCO could not certify the model EA170-51100 switch as a replacement switch because of a lack of traceability for the standard off the shelf switches. NAMCO stated that there is no Appendir B control of drawings and bills of materials for the standard switches. Masonellan conveyed this to WCNOC along with the fact that Masoneilan had previously certified similar spare switches (model EA170-11100) fcr use at WCGS.

Upon discovery of this situation, WCNOC reviewed the procurement history of limit switches supplied by Masoneilan. During the construction phase at WCCS, several control valves were procured from Masoneilan (Dresser Industries, Inc. , Hasonellan North American Operations, 85 Budwell Street, Avon, MA 02322) for use at WCGS. These control valves, which contained NAMCO lbnit switches (model EA170-11100), were environmentally and seismically qualified by Masoneilan in accordance with IEEE 323 and 344. Subsequently, model EA170-11100 NAMCO limit switches were ordered for WCGS as spares and supplied by Masonellan. Five purchase orders with Masonellan to order spare limit switches (model EA170-11100) were found in which a total of 97 switches were procured. Although, during contract negotiations, Masonellan indicated the switches were commercial grade items, Masonellan certified the switches as qualified per IEEE 323 and 344. Furthermore, this certification was to the purchase orders, which also invoked 10 CFR 50 Appendix B and 10 CFR 21. Prior to the 1988 procurement, the Masonellan program appeared to adequately control spare parts procurement. This was based on the Masonellan certification and on a sampling evaluation of Masonellan certifications during onsite audits and surveillance of other material procurement. However, based on the disclosures discussed above, coupled with results of recent WCN00 surveillance, WCNOC has determined that there is a lack of design control and material traceability associated with these switches. Therefore, WCNOC considers Masonellan's past certification of model EA170-11100 switches supplied as spares to be in error.

Further review of Masonellan procurement has determined that five of the 37 switches were issued to the field for use in four control valves. In order to determine acceptability of the switches which are installed at WCGS, an engineering evaluation was conducted to determine the acceptability of using the switches already installed in the four control valves. This evaluation determined that the installed switches were acceptable for interim use until qualified replacement switches are installed. To prevent further switches from being issued to the field, the switches procured from the five purchase orders have been put on QC hold until an evaluation can be conducted to determine the final disposition for these switches.

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, yAtt,achment to WM 89-0218  !

Page" 2 of 2' l

Subsequent .to the discovery of the improper ' certification of NAMCO limit  !

switches .by Masoneilan, WCNOC's Supplier / Materials Quality organization conducted a surveillance program on Masoncilan. WCNOC concluded thst for spare parts procured by Masoneilan and further conditioned through additional manufacturing . processes or assembly, that adequate design controls exist as verified during previous audits and surveillance. However, for. spare parts that do not require further conditioning, such as NAMCO lLait switches and ASCO solenoid valves, the controls evaluated were inadequate. The purpoes of this surveillance program was to evaluate the design and materials control of spare / replacement parts for nuclear service control valves supplied to WCGS by Masoneilan. During the surveillance program, design documents were evaluated, receipt inspection activities were witnessed, and the documentation associated-with certain procurement documents was evaluated.

This surveillance program showed that Masoneilan could not present objective evidence of design control nor provide a basis for certifying conformance to WCNOC purchase order requirements for certain spare / replacement electrical parts for nuclear service control valves. The specific parts in question are NAMCO limit switches (model EA170-11100) and ASCO Solenoid Valves. The surveillance showed that Masoneilan could show evidence of design control and a basis for certifying conformance for all other spare / replacement parts audited. and therefore corrective steps could be limited to the spare / replacement electrical parts. In older to assess the safety significance of procuring these items fran Masonellan, a review was performed by WCNOC to determine if any of the NAMCO switches or ASCO Solenoid Valve replacements were installed at WCGS. This review determined that only the five NAMCO EA170-11100 switches discussed above are installed at WCGS. The remaining NAMCO switches and ASCO Solenoid Valves have been put on hold in the warehouse to prevent them from being used in the future.

Since the electrical spare / replacement parts discussed above were incorrectly certified by NV -eilan, this situation has been determined to be a deviation from the techn. I requirements of the procurement document as defined in 10 CFR 21. As a deviation which could have created a substantial safety hazard.

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it is considered to be reportable as a defect pursuant to 10 CFR 21.

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