ML20247H106

Insp Rept 99901251/98-01 on 971020-21 & 980304-06.No Violations Noted.Major Areas Inspected:Implementation of Selected Portions of Commercial Quality Assurance Program

ML20247H106
Person / Time
Issue date:	05/14/1998
From:	NRC (Affiliation Not Assigned)
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Shared Package
ML20247H087	List: ML20247H084 ML20247H106
References
REF-QA-99901251 99901251-98-01, 99901251-98-1, NUDOCS 9805210065
Download: ML20247H106 (10)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Report No.: 99901251/98-01 Organization: GNB Technologies 829 Parkview Boulevard Lombard, Illinois 60148-3249

Contact:

Loranne M. May Quality Assurance Manager (630) 691-7949 Nuclear Industry: Manufacture of Vented Lead-acid Battery Cells" Dates: October 20-21,1997, Lombard, Illinois - Corporate Office March 4-6,1998, Forth Smith, Arkansas - Manufacturing Facility Team Members: Kamalakar R. Naidu, Team Leader Stephen D. Alexander, HOMB, NRR David L. Skeen, PECB, NRR Joseph J. Petrosino, HQMB, NRR Saba N. Saba, EELB, NRR Approved by: Richard P. Correia, Chief Reliability and Maintenance Section Quality Assurance, Vendor Inspection and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation The manufacture and control of Class 1E battery cells at the GNB Fort Smith manufacturing facility is performed in conjunction with Nuclear Logistics incorporated (NLI), Fort Worth, Texas.

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9905210065 990514 PDR GA999 EMVONBB 99901251 PDR l

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1. INSPECTION

SUMMARY

During this inspection, the NRC inspectors reviewed the implementation of selected portions of the commercial quality assurance program that GNB Technologies' (GNB) had established for its Lombard, Illinois corporate office, and Fort Smith, Arkansas flooded battery cell manufacturing facility. In August 1991, GNB entered into a contractual agreement with Nuclear Logistics, l

' Incorporated, (NLI) to manufacture Class 1E qualified vented lead-acid battery cells. This affiliation between the two entities required NLI to accept NRC licensee purchase orders for Class 1E battery cells and to invoke applicable portions of its quality assurance (QA) program to control certain safety-related activities. The agreement between NLI and GNB had provisions for NLl to monitor GNB's manufacturing process controls to ensure that the applicable portions of 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," were applied. Additionally, since NLl reconciled GNB's design changes and test reports of its commercial grade NCX flooded battery cells to establish a Nuclear Class 1E battery cell, NCN type, the NRC inspected both NLI and GNB activities. The findings related to NLI are documented separately in Inspection Report 99901298/98-01.

The inspection bases were Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50, Appendix B).

10CFR Part 21, " Reporting of defects and noncompliance,"(Part 21).

L. STATUS OF PREVIOUS INSPECTION FINDINGS.

This was the first inspection of these GNB facilities.

3. INSPECTION FINDINGS AND OTHER COMMENTS.

3.1 GNB Quality Assurance Proaram GNB Technologies has established a quality program to address the requirements of an International Organization for Standardization (ISO) 9000 quality system at both of its facilities that are associated with nuclear power plant Class 1E battery cells. GNB has established an ISO 9001, *Model for Quality Assurance in Design, Development, Production, installation and Servicing," for its Lombard, Illinois, corporate office and an ISO-9002, "Model for Quality Assurance in Production, installation and Servicing," for its Fort Smith, Arkansas, vented lead-acid battery cell manufacturing facility. The GNB Quality Manual (GNB-QM), Revision OB, effective date March 14,1997, states that the GNB-QM sets forth the quality policies of GNB and forms the conceptual foundation for the quality system in place within GNB and is structured to meet the requirements of ISO-9001. The GNB-QM also states that it is the primary reference document for the purpose of auditing the effectiveness of the quality system and all remaining quality system documentation is subordinate to and supportive of the manual.

' GNB is a wholly owned subsidiary of Pacific Dunlop Limited of Australia. In approximately 1899, Gould National Batteries was established and eventually became GNB.

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The inspectors reviewed selected portions of GNB's quality system that were associated with the manufacture of Class 1E safety related batteries, and that were associated with the quality program which NLI used to assure itself that the applicable GNB quality requirements met the quality requirements of 10 CFR Part 50, Appendix B.

3.1.1 Enaineerina Desian Chance Control

a. Scope The team assessed the efficiency and adequacy of the design of the battery cells that were qualified to withstand the environmental conditions of various nuclear power plants. The team reviewed GNB Procedures DC-99-00-ENG " Engineering Change Order Approval, implementation and Distribution Process," Revision OE, of December 23,1996, and 99-01-ENG, " Deviation Approval, Implementation and Distribution Process," Revision ED, that address the control of engineering change orders (ECOs).

b. Observations and Findings The inspectors reviewed various documents and conducted inspections at both the Lombard and Fort Smith GNB facilities. Procedure DC-99-00-ENG, outlines procedures for processing, approval requirements and responsibilities with regard to the issuance of ECOs. Section 7.4.1 of this procedure requires GNB to identify design and manufacturing changes to all flooded stationary batteries to NLI so that NLI can evaluate them for impact upon the qualification of batteries and components provided for class IE applications. Procedure DC-99-01-ENG, outlines the steps for processing, approval requirement and responsibilities with regard to the issuance of deviations from existing specification and procedures. The procedure provides instructions on completing a Deviation Form, its approval routing, implementation procedure for a ' Deviation,' '

and distribution, closure and retention of a ' Deviation.' Any individual on the routing slip could reject the design change and provide reasons for rejection.

The team reviewed ECO 9700,653 issued on October 12,1997, to revise Specification PR 09-ALL, " Cell Storage and Maintenance for Stationary Flooded and VLRA Cells," to reflect the change in the requirements to document the recharging and equalizing data. After reviewing this ECO, NLI determined that the ECO did not impact batteries intended for safety-related applications, and requested that the ECO be placed in the GNB ECO/ Deviation binder ma'..lained at NLI. However, there was a notation to review the acceptance criteria when NLl's Procedure, " Standard Verification Plan GNB Batterie.s and Hardware," (SVP-31) was being ,,

revised to verify if there was alread)a requirement'airead3therein to document the recharging "'

and equalizing data. It alsh requ~ested the ECO be'placeId in the designated NLI binder for GNB Process Specification.

GNB's design change control appeared to be satisfactorily implemented and controlled in accordance with its quality system requirements. However, the inspectors noted an anomaly between the GNB and NLI quality system interface during its Lombard facility inspection.

Although NLI stated that it concurred with GNB's changes for its Class 1E cells, the inspectors determined that GNB approved all Class 1E design changes without NLI concurrence. After GNB completed its design change, GNB routed the completed design changes to NLI. During the inspection at the Fort Smith facility, the inspectors leamed that NLI and GNB had changed the ECO process in response to an earlier NRC inspector's comment. GNB changed its ECO process to include NLI in its design change request process concurrence. The team did not attempt to verify whether the previous practice of informing NLl of the design change (versus concurring with the change) affected any battery cells being manufactured.

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c. Conclusions The team did not identify any adverse findings in this area related to GNB activities.

3.1.2 Control of Vendors

a. Scope

, The inspectors reviewed the procedure for controlling purchased material and services, Quality l

Control Procedure (QCP) 604, " Supplier Selection," Revision OE, dated July 22,1997, and QCP 600, " Supplier Performance Measurement System," Revision OB, dated July 22,1997.

b. Observations and Findinas QCP 604 requires GNB QA to conduct a survey to compile information on a new vendor and conduct an audit if necessary utilizing a check list of attributes to be verified. The procedure requires OA, Engineering, and Purchasing to jointly approve both the selection and rejection of any vendor. OCP 600 outlines the details of the supplier performance measurement system which requires compilation of feedback from other GNB plants. The feedback information is derived from other GNB plants during receipt inspections when personnel at those facilities observe various attributes, such as, quality performance, timely delivery of the goods, total cost of the goods, technical / engineering support from the vendors, and paper work / communication response time. This information is forwarded to the corporate QA which accumulates data for the supplier performance measurement system. The various GNB manufacturing plants are required to issue corrective action requests to the vendors when they observe conditions adverse to qualityin the products they supplied.

At the Fort Smith facility, the team observed an NLI memorandum of October 6,1997, which indicated that GNB's activities associated with " procurement document control and... control of purchased material (receipt inspection)" exhibited a " quality system breakdown." The NLI memorandum was written by the then NLI QA Manager which documented a limited scope assessment of the Fort Smith facility that was performed by the QA Manager and Vice President

[former QA Manager) of NLI. Based on NLi's findings the memorandum identified an " action item list" for NLl and GNB personnel to correct and verify concerns that were found, instead of documenting the concems on an audit report or nonconformance report.

Additionally, another NLI memo, dated September 29,1997, stated in part " based upon the limited scope assessment performed at GNB-Lombard, Illinois, on September 25,1997, that there has been a quality system breakdown in document control and vendor assessment."

c. Conclusions The NRC inspectors observed that NLI did not document the adverse comments identified in its October 6,1997, memorandum in a nonconformance report. This memorandum identifies that weaknesses may exist in the establishment or implementation of GNB's activities in other areas of the control of vendors. The team verified the adequacy of GNB's control of Amerace which supplies separators manufactured by its Micro Porus Products, Inc. division located in Piney Flats, Tennessee. GNB QA had completed a survey of Micro Porus Products in 1993.

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3.1.3 Trainina of Personnel

& Scope The team reviewed the training imparted by GNB to its auditors by reviewing QCP-1700,

" Qualification Trainees," Revision OB, dated February 19,1998, and QCP-1800, " Training,"

Revision OB of August 8,1997.

b. Observations and Findinas QCP-1700 prescribes the qualification of the auditors and describes the auditor training program.

QCP-1800 outlines the training requirements for all employees performing activities affecting quality. The team reviewed the qualifications of three individuals and determined that they were adequately qualified.

c. Conclusions The team identified no adverse findings in this area.

3.1.4 Corrective Action Proaram

a. Scope The team assessed the adequacy of the GNB's corrective action program by reviewing QCP- 1 1402, " Corrective Action (General)," Revision QA, of April 19,1996, QCP-1601, " Customer  !

Complaint Corrective Action Program," Revision OE, of November 12,.1996, and Lombard Work '

Instruction LWl-1500-14.

b. Observations and Findinas QCP 1402 outlines the corrective actions that are required from suppliers and customer complaints. OCP-1601 outlines the actions taken by GNB regarding customer complaints. This procedure applies to all customer complaints against product manufactured by GNB except for batteries intended for submarine applications. LWl-1500-14 describes the steps to be followed i by GNB personnel for processing NLl claims and defines the interrelationship between NLI and i GNB Warranty Department when processing claims. The GNB Team Leader- Flooded / Military and New Business Products is responsible to initiate a root cause analysis to determine the cause of failure. This procedure has been developed recently and is in the approval stage.

c. Conclusions The team was unable to assess this area because the procedure has not been implemented.

3.2 Manufacturing Process Controls Strap Bumina of Vented Lead-Acid Stationary Batterv Cells

a. Scope At the GNB's Fort e siith, Arkansas facility, the NRC inspectors observed Class 1E safety-related l plate / separator assembly, and positive / negative plate lug-to-bus bar fusion process (strap buming) of four NCN-21 type battery cells to assess the effectiveness of the processes. These 5

i four safety-related cells were part of two 60-cell batteries intended for the Baltimore Gas and '

Electric Company's (BG&E) Calvert Cliffs nuclear power plant. The applicable BG&E purchase order (PO), PO 18995, dated January 15,1998, was for two 60-cell NCN-21, batteries, and these 1 were the last four of the 120 cells to be built.

b. Observations and Findings The inspectors observed GNB craftsmen, known as burners, assembling certain components of the four BG&E battery cells to assess the adequacy and appropriateness of the manufacturing process controls, and to observe the value added by the NLI QA inspection personnel who ensure that the process is within allowable manufacturing parameters. The process included the fusion of lead bus bars (called " straps") to the individual positive and negative plate lugs. The inspectors observed that the burners were not performing the task as described in the GNB Fort Smith Standard Operating Procedure (FSOP)-06-02, " Strap Buming of Flooded Stationary Cells."

The FSOP called for the burner to first melt the strap " fingers" and plate lugs with his torch, then melt lead sticks to fill to the top of the mold, and stir the mixture with a stainless steel rod (stir stick), and finally repeat the last step. However, contrary to the FSOP, the bumer was observed to first add some molten lead to the bus bar and plate lugs, then melt the mixture together and stir it with the stir stick. He then made another pass over the mixture to smooth the top surface and to blow off any residual slag.

Step 13 and 14, " Element Buming," of GNB's Flooded Assembly Operator Training and Certification Manual, Revision AA, no date indicated, described the strap-to-lug " double bum" process. The training manual calls for the bumer to make two passes with the stir stick to ensure adequate depth of fusion between the bus bar and the plate lugs. When asked to describe the double burn process, neither of the bumers interviewed nor their first line supervisor were aware that a double bum required two passes with the stir stick. They believed that one pass with the stir stick and another pass to blow off slag and mix the upper portion of the bus bar l and plate lugs together was the double bum process. When asked why lead was first added to the bus bar and plate lugs before melting them together, the burners stated that because of the loose fit of the molds, it was necessary to first add lead to prevent bum-through during the melting process that would result in molten lead running out of the bottom of the mold. The first j line supervisor independently confirmed that the burn process could involve adding a small l amount of molten lead before melting the strap fingers and plate lugs on the smaller size cells such as, the NCN-21.

GNB management stated that the FSOP was originally developed by a corporate GNB engineer specifically for the larger H type cells and that it may not be appropriate for the smaller cells such as, NCN-21s, but they were not aware that the bumers were not performing the bum as written in the FSOP. According to GNB, the double bum process was instituted a few years ago on H-series cells, which use thicker bus bars and plates than the N-series cells, after GNB experienced some problems with inadequate fusing during the buming process. The double bum was meant to achieve a deeper penetration of the bus bars and stirring the mixture twice was supposed to ensure adequate mixing and fusing. The process worked so well on the H-series cells that it was decided to post the FSOP at all of the assembly floor bum work stations, including the stations where the N-type cells were assembled. As a result of the questions

! raised by the NRC inspectors, GNB management stated that the double burn process would be reevaluated in regard to the NCN-series cells and that all burners would receive training on the double buming process.

The inspectors interviewed the NLI QA personnel at the GNB Fort Smith facility. NLI QA is responsible for witnessing the buming process for nuclear grade NCN-series batteries to assure that the GNB bumers were implementing Procedure FSOP-06-02. Overall, the QA personnel 6

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were knowledgeable of the manufacturing process and understood the NLI procedures governing oversight of the process. However, none of the NLi QA personnel understood the double bum process and believed that the double bum process consisted of a single pass to add melted lead and the second pass was to stir the mixture together with the stainless steel rod. When asked about training, the NLI personnel stated that most of their training for the different process controls was performed by on-the-job training from the senior or previous NLI personnel. The inspectors determined that the NLI QA Manual did not require the NLt QA inspectors to read and understand the GNB engineering requirements or specifications to familiarize themselves with the GNB procedures governing the buming process.

The NRC inspectors also observed two other types / sizes of battery cell bus bar/ plate lugs being fused, the M, and H type of cells. The M cell was smaller than the NCN-21 and the H was larger than the NCN-21. Both the H and M cells are commercial GNB battery cells that are not used in safety-related applications. The inspectors observed that the burner who was assigned to an H type cell did use the double burn method which was delineated in the FSOP posted at the work station.

The controlling GNB specification for the FSOP is PR-14-05-FST, " Assembly Process for Flooded Stationary Cells-Fort Smith," Revision OD, October 22,1997. GNB's Specification PD-14-00-FST, " General Engineering Requirements for Flooded Stationary Cells," Revision OC, October 22,1997, and GNB Flooded Assembly Operator Training and Certification Manual, Revision AA, no date indicated, are also applicable. NLI had also established inspection requirements in NLl SVP-31, " Standard Venfication Plan GNB Batteries and Hardware," Revision 11, December 1997. However, when all of the different documents and processes were compared with each other, inconsistencies were noted by the inspectors, specifically; Step 13, in the " Process Observation-Element Buming," of the GNB Flooded Assembly Operator Training and Certification Manual did not contain adequate verbatim information to ensure consistency in the strap buming process. It was unclear as to the particular point in time when extemallead is supposed to be added to the lug-bus barjunction. The manual narrative is also different from the FSOP; therefore, the quality and adequacy of the bum may be indeterminate.

The sequence for the strap bum specified in the FSOP was determined to be inappropriate for the smaller N type battery cells.

When the NRC inspectors asked the shop supervisor to explain the correct method of performing double strap burn, he described almost exactly what the inspectors observed GNB's operator doing on the NCN-21 cells, which was not in accordance with the FSOP.

PR-14-05-FST, Revision OD, requires: the maximum acceptable depth of bum of the plate lug to strap shall be 75% of the lug; conversely, PD-14-00-FST, Revision OC, requires: the minimum acceptable depth of bum of plate lug to strap shall be 75%.

Although GNB engineering specified a 75% depth-of-bum value, neither GNB's Operator Training and Certification manual, FSOP, nor NLi's SVP-31 addresses the 75%

acceptance value for process control or verification aspects. In fact after observing the process, the NRC inspectors concluded that it would be difficult for either the GNB bumer or NLI QA inspector to determine whether the actual depth-of-bum is close to 75%.

. The narrative sequence and order of the bum events differ between the FSOP and Operator Training and Certification Manual 7

When the NLI and GNB management were initially informed of the observations by the NRC inspectors, the senior GNB officer, the Vice President of Technology and Quality Assurance, stated to the NLI Vice President and NRC inspectors that GNB had decided to immediately remove the bumer's certifications and start the process of terraination from GNB because the operator did not follow the FSOP. The NRC inspectors informed GNB and NLI management that punishing the bumer might be in conflict with 10 CFR 50.7, " Employee Protection" regulations, l

because the activities being under 10 CFR 50, Appendix B could, in fact be, " Protected Activities". Therefore, the inspectors stated that they would have to contact the NRC Office of General Counsel for guidance. Consequently, three of the five NRC inspectors interrupted their respective inspection activities and started to obtain additional information regarding this matter.

The NRC inspectors conducted interviews with other strap buming operators, the shop supervisor for the applicable area, the Plant Operations Manager, Manager of Process Engineerin0 and NLl QA Inspectors to comprehensively evaluate the matter and determine if there was intimidation by GNB management.

As a result of this interruption for the additional effort, the NRC inspectors could not complete some of the other areas that they had planned to review.

c Conclusions The NRC inspectors concluded thot several weaknesses existed regarding the establishment and implementation of the strap bum process. For example, operator training instructions did not contain adequate verbatim requirernents to assure that the process was consistent in the quality of the finished product, especially be, ween different operators; first line supervision was not aware of procedural requirements anc therefore did not notice failure to comply with the requirements; NLI QA inspectors were unaware of procedural requirements and, therefore, failed to notice noncompliance with the requirements; GNB did not appear to have an engineering justification to implement the double bum process to the Class 1E N-type cells; and the NLI QA personnel, while having an overall knowledge of the manufacturing process from the NLI procedures and via on the job training from previous NLI personnel, were not required to read and understand the basis for the process controls. This is considered a weakness in the GNB and NLI quality assurance programs. After interviewing the GNB and NLl personnel, the inspectors determined that it was not necessary to contact the NRC Office of General Counsel because they observed that the GNB and NLI personnel had not been intimidated by their management and the issue did not cause a chilling effect on the workers. The NRC team's actions for NLI to address this matter as related to safety-related items are identified in inspection Report 99901298/98-01.

3.3 Observation of Manufacturing Activities at Fort Smith. Arkansas

a. Scope Observe activities in progress to verify the implementation of NLI quality assurance program rud GNB quality program during the manufacture of batteries at Fort Smith,

b. Observation and Findinas The team accompanied by GNB personnel toured the facilities and observed batteries intended for Arizona Public Service Company's Palo Verde plant being tested and batteries intended for Baltimore Gas and Electric Company's Calvert Cliff's plant being manufactured. The team observed that NLI quality Control (QC) inspectors affix a GNB yellow " hold" tag to items which S

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require their verification and release. The NLi inspectors establish hold points on a traveler to remind the GNB personnel that NLI personnel are required to sign-off before GNB can commence the next manufacturing step. Typical hold points have been established for the following operations when NLIinspections have to determine that the manufactured component I has met the applicable GNB acceptance criteria.

1 Verification that only Columbus Red Lead oxide is used. l Cube weight, rod penetration and Active Material Apparent Density (AMAD) is documented for each paste mix lot.

Verify that the finished plate weights and dimensions meet the applicable requirements.

Verify that only approved busbars and plates are used for cell assembly and that the burn of the p!ates to the busbar are " double pass" and meet GNB specifications.

Verify that the measured terminal to terminal resistances and the terminal to plate resistance are within the specifications limits.

Perform 100-percent verification of post alignment and post seal nuts torque on the assembly line meet the applicable acceptance criteria.

Witness and record the results of the celileak test (cell will hold 1 psig for 30 seconds) l Verify that cells are filled with electrolyte for a minimum of one hour. This includes '

monitoring the cell temperature, and at least two 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> let downs.

After the formation, witness discharge tests to measure and document battery capacity.

The NRC team witnessed a performance test being performed on four NCN 31 type cells. The measuring instruments recorded the voltage at the battery, and each individual cell during the test showing the " Coup de Fouet" dips, the voltage recovery and the voltages at the end of the test. The inspectors observed that the capacities of these cells were over 100%.

The inspectors observed that the following are the major differences between the GNB commercial-grade and safety-related battery cells:

The cells that are manufactured for NLI which are intended for nuclear utilities are certified that the battery rneets Class IE requirements.

A traveling tag (Hold Tag) is used along the production line as a hold for NLI inspectors.

" Columbus Oxide" is used for the Class IE cells.

Torquing of the post seals is done by NLI personnel.

The AMAD values for positive plate are 3.45 - 3.60 gle.c. a more restrictive low range to allow a possible higher value of capacity testing.

The formation of the Class IE cells is different from commercial grade. The Class IE will be subjected to at least two 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> let down while the commercial grade is subjected to 9

one 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> let down.

c. Conclusion The team did not observe any adverse findings in this area.

4. Personnel GNB Technologies Lombard. Il!inois J. Jergl Vice President, Technology & Quality Assurance L.May - Quality Assurance Manager L. Joubert Purchasing Coordinator M. Linne After Sales Manager

K Perzee Director Procurement B.Sheehan Document Control S.Vechy Utility Sales & Marketing Manager l J. Boehm Product Engineer R. Schmitt Team Leader Flooded / Field Engineering NRC inspectors met the above persons 'during October 20-21,1997.

GNB Technologies. Fort Smith. Arkansas M. Schessler Operations Manager J. Reinhard Manager of Process Engineering & Quality Assurance

! The NRC inspectors met the above personnel during March 4-6,1998.

Nuclear Loaistics. Incorporated. Fort Worth. Texas A. Bell Vice President 2 R Bonisolli Quality Assurance Manager3 W. Malik Project Manager l

2 Mr. Bell was the NLI QA Manager during the Fort Smith facility inspection.

' Mr. Bonisolli was the QA roanager during the Lombard facility inspection. I i

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