ML20247N303
| ML20247N303 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0040, NUREG-0040-V13-N02, NUREG-40, NUREG-40-V13-N2, NUDOCS 8909260186 | |
| Download: ML20247N303 (54) | |
Text
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NUREG-0040 Vol.13, No. 2 Licensee Contractor and Vendor Inspection Status Report I
i Quarterly Report April 1989 - June 1989 i
U.S. Nuclear Regulatory Commission
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Available from Superintendent of Documents l
U.S. Government Printing Office Post Office Box 37082 Washington, D.C. 20013-7082 A year's subscription consists of 4 issues for this publication.
Single copies of this publication l'
are available from National Technical information Service, Springfield, VA 22161 i
l t
NUREG-0040 Vol.13, No. 2 Licensee Contractor l
and Vendor Inspection
. Status Report l
l Quarterly Report April 1989 - June 1989 Manuscript Completed: August 1989 Date Published: August 1989 Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 ynnec s.....
i
1 ABSTRACT l
I This periodical covers the results of inspection performed by the NRC's Vendor Inspection Branch that have been distributed to the inspected organization during the period from April 1989 through June 1989.
iii
I TABLE OF CONTENTS PAGE Abstract......
iii Preface vii Reporting Format...........................
ix Index xi Inspection Reports.........................
1 List of Selected Bulletins and Information Notices Concerning Adequacy of Vendor Audits and Quality of Vendor Products........
42
.4 Tabic of Vendor Inspection Reports Re1#tte to Reactor Plants............ <.............
43 v
1 i
PREFACE A fundamental premise of the Nuclear Regulatory Commission's (NRC) nuclear facility licensing and inspection program is that licensees are responsible for the proper construction and safe operation of their nuclear power plants.
The total government-industry system for the inspection of nuclear facilities has been designed to provide for multiple levels of inspection and verification.
Licensees, contractors, and vendors each participate in a cuality verification process in accordance with requirements prescribed by, or consistent with, NRC rules and regulations.
The NRC inspects to determine whether its requirements are being met by a licensee and his contractors, while the great bulk of the inspection activity is performed by the industry within the framework of ongoing quality verification programs.
In implementing this multilayered approach, a licensee is responsible for developing a detailed quality assurance (QA) plan. This plan includes the QA programs of the licensee's contractors and vendors.
The NRC reviews the licensee's and contractor's QA plans to determine that implementation of the proposed QA program would be satisfactory and responsive to NRC regulations.
In the case of the principal licensee contractors, such as nuclear steam supply system designers and architect engineering firms, the NRC encourages submittal of a description of corporate-wide QA programs for review and acceptance by the NRC.
Once accepted by NRC, a corporate QA program of a licensee's contractor will be acceptable for all license applications that incorporate the program by reference in a Safety Analysis Report (SAR).
In such cases, a contractors's QA program will not be reviewed by the NRC as part of the licensing review process, provided that the incorporation in the SAR is without change or modification. However, new or revised regulations, Regulatory Guides, or Standard Review Plans affecting QA program controls may be applied by the NRC to previously accepted QA programs.
When design and construction activities were high, firms designing nuclear steam supply systems, architect engineering firms designing nuclear power plants, and certain selected major equipment vendors were inspected on a regular basis by NRC to ascertain through direct observation of selected activities whether these design firms and vendors were satisfactorily implementing the accepted QA program.
However, with the substantial decline of new plant design activities, the inspection of QA program implementation has been deemphasized.
Instead, the NRC vendor inspection focus has been shifted to vendor activities associated with nuclear plant operation, maintenance, and modifications.
Inspection emphasis in now placed on the quality of the vendor products including hardware fabrication, licensee-vii
vendor interfaces, environmental qualification of equipment, and equipment problems found during operation and corrective action.
If nonconfonnances with NRC requirements and regulations are found, the inspected organization is requested to take appropriate corrective action and to institute preventive measures to preclude recurrence.
If generic implications are identified, NRC l
assures that affected licensees are expeditiously informed.
l l
In addition to the above, the Vendor Program Branch has begun inspections at l
licensee facilities covering the areas of procurement of replacement parts for use in safety-related systems and licensee / vendor interface programs as requested in Generic Letter 83-28. This edition of the White Book contains copies of the inspection reports of inspections completed to date.
Subsequent issues will contain those reports that are issued in the quarterly report period covered by that White Book.
In the past, NRC issued confirming letters to the principal contractors to indicate that NRC inspections have confirmed satisfactory implementation of the accepted QA programs.
Licensees and applicants could, at their option, use the letters to fulfill their obligation under 10 CFR 50 Appendix B, Criterion VII, that requires them to perform initial source evaluation audits and subsequent periodic audits to verify QA program implementation.
- However, based on the above described change in nuclear plant design and construction activities, NRC will no longer issue confirming letters to principal contractors since future NRC vendor program inspections will focus on selected areas rather than addressing the implementation of their respective QA programs. Therefore, cor. firming letters that have already exceeded their three year effective period will not be renewed.
Confirming letters issued less than three years ago will l
remain in effect until the stated effective period expires.
Therefore, as the l
confirming letters expire, licensees and applicants will no longer be allowed l
to take credit for the NRC acceptance of the implementation of a principal contractor's QA program.
Licensees continue to be responsible for the conduct of initial source evaluation audits and subsequent periodic audits to verify QA program implementation.
The White Book will continue to be published and will contain copies of all vendor inspections issued during the calendar quarter specified.
The vendor inspection reports list the nuclear facilities to which the results are applicable thereby informing licensees and vendors of potential problems.
In addition, the affected NRC Regional Offices are notified of any significant problem areas that nay require special attention.
The White Book also con-tains copies of If,E Information Notices, concerning vendor issues released during the calendar quarter.
The White Book contains information normally used to establish a " qualified suppliers" list; however, the information contained in this document is not adequate nor is it intended to stand by itself as a basis for qualification of suppliers.
Correspondence with contractors ana vendors relative to the inspection data contained in the White Book is placed in the USNRC Public Document Roon, located in Washington, D.C.
I viii
1c ORGANIZATION: COMPANY, DIVISION ~
CITY, STATE REPORT.
INSPECTION INSPECTION NO.: Docket / Year / Sequence DATE:
ON-SITE HOURS:
CORRESPONDENCE ADDRESS:
Corporate Name-Division ATTN:
Name/ Title Address City, State Zip Code ORGANIZATIONAL CONTACT: Name/ Title TELEPHONE NUMBER:
Telephone Number NUCLEAR INDUSTRY ACTIVITY: Description of type of components, equipment, or services supplied.
ASSIGNED INSPECTOR:
Name/ Vendor Program Branch Section Date OTHER INSPECTOR (S):
Name/ Vendor Program Branch Section APPROVED BY:
Name/ Chief - Section/ Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
Pertain to the inspection criteria that are applicable to the activity being inspected; i.e., 10 CFR Part 21, Appendix B to 10 CFR Part 50 and Safety Analysis Report or Topical Report commitments.
B.
SCOPE: Summarizes the specific areas that were reviewed, and/or identi-fies plant systems, equipment or specific components that were inspected.
For reactive (identified problem) inspections, the scope summarizes the problem that caused the inspection to be performed.
PLANT SITE APPLICABILITY: List plant name and docket numbers of licensed facilities for which equipment, services, or records were examined during the inspection.
1 ix l
ORGANIZATION: ORGANIZATION CITY, STATI REPORT INSPECTION NO.:
RESULTS:
PAGE 2 of 2 A.
VIOLATIONS:
Shown here are any inspection results determined to be in violation of Federal Regulations (such as 10 CFR Part 21) that are applicable-to the organization being inspected.
B.
NONCONFORMANCES:
Shown here are any inspection results determined to be in nonconformance with applicable commitments to NRC requirements.
In addition to identifying the applicable NRC requirements, the specific industry codes and standards, company QA manual sections, or operating procedures which are used to implement these commitments may be referenced.
C.
UNRESOLVED ITEMS:
Shown here are inspection results about which more
)
information is required in order to determine whether they are acceptable
{
items or whether a violation or nonconformance may exist. Such items will l
be resolved during subsequent inspections.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS: This section is used to identify the status of previously iden'tified violations, items of nonconformance, and/or unresolved items until they are closed by appropriate action.
For all such items, and if closed, include a brief statement concerning action which closed the item.
If this section is omitted, all previous 4
inspection findings have been closed.
E.
INSPECTION FINDINGS AND OTHER COMMENTS: This section is used to provide I
significafit information concerning the inspection areas identified under
" Inspection Scope."
Included are such items as mitigating circumstances concerning a violation or nonconformance, or statements concerning the limitations or depth of inspection (sample size, type of review performed and special circumstances or concerns identified for possible followup).
I For reactive inspections, this section will be used to summarize the disposition or status of the condition of event which caused th,e inspection to be performed.
F.
PERSONS CONTACTED: Typed, Name, Title
- present during exit meeting i
SAMPLE PAGE (EXPLANATION OF FORMAT AND TERMIN0 LOGY)
X
1 INDEX REPORT NUMBER PAGE 99900742/89-01 1
e,11 kn S
i l
Square D Company 99903146/89-01 19 Cedar Rapids, Iowa 999 0225/89-01' 29 oro, Na sa husetts xi
INSPECTION REPORTS
l l
ORGANIZATION: THE ROBERT IRSAY COMPANY
-SK0KIE, ILLINDIS 60076 REPORT INSPECTION INSPECTION NO.: 99900742/89-01 DATE:. January 23-27, 1989 ON-SITE HOURS: 68 l
CORRESP'sNDENCE ADDRESS: The Robert Irsay Company 8130 North St. Louis Avenue Skokie, Illinois 60076 ORGANIZATIONAL CONTACT:
R. Kawalek TELEPHONE NUMBER:
312-674-8500 NUCLEAR INDUSTRY ACTIVITY: Fabricates and installs heating, ventilating, and air conditioning ductwork.
ASSIGNED INSPECTOR:
6hM2 f/ '
' K. R. Naidd', Reactive Inspection Section No. 1 e
(RIS-1)
OTHER INSPECTOR (S):
W. I. Shier, Brookhaven National Laboratories
([
M APPROVED BY:
/
,3.
T. BaMr, Chief, RIS-I, Vendor Inspection Branch O M.e E
INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and 10 CFR 50, Appendix B.
B.
SCOPE:
Reviewed the implementation of The Robert Irsay Company (RICO) quality assurance program in several areas, observed manufacturing activities in progress at Skokie, Illinois,(HVAC) ductwork activities and the installation of heating, ventilating, and air conditioning at the Quad Cities nuclear power plant.
PLANT SITE APPLICABILITY: Dresden 2 & 3 (50-237/249), Quad Cities 1 & 2 (50-254/255), Kewaunee(50-305).
1
l ORGANIZATION: THE ROBERT IRSAY COMPANY SK0KIE, ILLIN0IS 60076 REPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 2 of 18 A.
VIOLATIONS:
No violations were identified during this inspection.
B.
HONCONFORMANCES:
1.
Contrary to Criterion X of Appendix B to 10 CFR 50, and Subsection 11.4 of Section 11 of the RICO Quality Assurance Manual (QAM), inadequate weld inspections were performed on fabricated ductwork in that stitch welds, attaching stiffeners to the ductwork, did not meet the design drawing requirements.
The ductwork was documented as acceptable and shipped as meeting the applicable design drawing requirements (89-01-01).
2.
Contrary to Criterion XVI of Appendix B to 10 CFR 50, measures are i
not established in Section 17 of the RICO QAM to take necessary 1
corrective action to correct adverse findings identified by external organizations, such as customers, and prevent their recurrence (89-01-02).
C.
UNRESOLVED ITEMS:
No unresolved items were identified during this inspection.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
Not applicable, this is the first NRC inspection of this facility.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Information on The Robert Irsay Company a.
Backgrcund Information RICO was established in January 1952 as an HVAC fabrication and installation contractor.
In 1958, RICO received a contract to fabricate and install HVAC ductwork at the Dresden Unit I nuclear power plant.
In the years to follow, RICO operated two other plants in Toledo, Ohio and Jackson, Mississippi, where HVAC-related components were manufactured and supplied to nuclear power plants. The Quality Assurance (QA) manager 2
ORGANIZATION: THE ROBERT IRSAY COMPANY SK0KIE, ILLINDIS 60076 REPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 3 of 18 stated that two years after the completion of the installation at the Grand Gulf nuclear power plant the Jackson office was closed. To date, RICO has performed HVAC work at 26 domestic nuclear power plant units. RICO is currently a wholly owned subsidiary of Jupiter Industries, Incorporated, Chicago, Illinois.
b.
Current Activities RICO is in the process of completing the installation of HVAC ductwork which was fabricated and shipped to the Dresden site to modify the existing HVAC system in the control room area. Also, RICO has commenced installation of the hangers to support the ductwork for Quad Cities to modify their control room HVAC system. The manufacture of one personnel access door for the Kewaunee nuclear power plant has been completed and is awaiting shipment, while three access doors intended for Quad Cities are scheduled for fabrication.
c.
Inspection Objective Conrnonwealth Edison Company (CECO) informed the flRC in January 1989 that CECO issued a "Stop Work" order on RIC0's activities.
CECO's action was based on adverse i
findings identified during receipt inspection of the ductwork received at Quad Cities and a subsequent audit at Skokie, Illinois.
Recently, CECO rescinded the "Stop Work" order and permitted RICO to resume installation work. The installation work is to be performed in accordance with Ceco's QA program instead of RICO's QA program.
This inspection was conducted to examine the implementation of the RICO QA program and to review the adequacy of the corrective action taken to resolve adverse findings identified by CECO.
2.
Review of Purchase Orders Received by RICO 1
a.
Commonwealth Edison Company Purchase Order
]
CECO purchase order (P0) 316979, dated Noveraber 2,1987, reovired RICO to fabricate and install ductwork in accordance with specification 0597-21-5-1 Revision 0, dated March 9, 1987, and Addendum No. 1, dated March 30, 1987, 3
- _ _ _ =
l ORGANIZATION: THE ROBERT IP,SAY COMPANY SK0KIE, ILLIN0IS 60076 PEPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 4 of 18 i
l 1
et the Dresden and Quad Cities Nuclear Power Plants. The P0 was followed by two change orders dated 11 arch 16,1988 and May 12, 1988. The P0 required compliance to 10 CFR 21 and 10 CFR 50, Appendix B.
Specification K-4080, dated July 15, 1986, specified the welding requirements which included compliance to American Welding Society (AWS)
D1.3-81 or D1.1-86, as applicable, and inspection require-ments of Nuclear Construction Inspection Group (NCIG)-01.
RICO designated Job Number 533 for the work to be performed for Dresoen and Job Number 534 for Quad Cities.
J l
b.
Wisconsin Public Service Corporation (WPSC)
]
1 WPSC issued P0 2702,. dated June 24, 1988 including Change I
l Order 1, dated August 25, 1988, to RICO for the supply of one 24 by 30-inch HVAC access door, intended for the Kewaunee nuclear power plant, complete with all hardware and accessories required for field installation into the existing ductwork.
The door was designated as a *Q" item and was required to be identified as *DCR-2259." The requirements of 10 CFR 50, Appendix B and 10 CFR Part 21 were imposed. Documentation and data required included outline drawings, Certified
!!aterial Test Reports (CMTRs) for all material except fasteners, Weld Procedure Specifications (WPS), WPS quclifi-cations, welder qualifications, certificates of conformance for fasteners and nonmetallic material, and installation instructions.
3.
Review of Control of Design Drawings The Midwest Regional Office of Impe11 Corporation (Impell) is the architect engineer (AE) for the modification of the HVAC systems at Dresden and Quad Cities.
Impell modified the drawings, originally prepareo by Sargent & Lundy (S&L) for this project, to define the current scope of work.
Impell also generated additional drawings necessary to supplement the revised S&L drawings. S&L drawing M-728 entitled " Service Building Floor Plan Elevation 623'-0, Control Room HVAC System Quad Cities 1 & 2," was revised by Impell in Revision J, dated June 15, 1988. S&L drawing M-401, entitled " Service Building Air Conditioning Ventilation Room," was revised by Impell in Revision W, dated June 15, 1988.
Impell gener-ated drawing M-599 Sheet 1 Revision C, dated June 15, 1988 entitled,
" Main Control Room HVAC Supports, Sections and Details" to supple-l ment the above drawings.
4
l ORGANIZATION:
THE ROBERT IRSAY COMPANY SK0KIE, ILLINDIS 60076 REPORT INSPECTION l
NO.: 99900742/89-01 RESULTS:
PAGE 5 of 18 RICO personnel prepared drawing QV-101, dated June 15, 1988, entitled " Control Room HVAC Upgrade," showing the generai layout of the modified HVAC ductwork.
RICO personnel at Dresden and Quad Cities prepared fabrication (Fab) tickets from these drawings taking into consideration the actual obstacles and interferences in the plant such as the existing cable tray and pipe hangers. The Fab ticket, which is an outline drawing, lists the bill of materials, and has provisions to document the fabrication ar.d inspection history. A Duct Brochure (DB) is prepared providing details to manufacture the ductwork.
Both the Fab tickets and the DB are required to be approved by Impell.
The Fab ticket serves as a traveller for the duct piece and when the item is completed, provides information relative to the welder, WPS used, weld material used, and the results of visual weld inspection. The NRC inspector reviewed several drawings and observed that rubber stamps were used by two individuals to denote approvals instead of actual signatures.
It was stated that due to the space limitations of the assigned signature box, the use of a rubber stamp was adopted in lieu of an actual signature.
The QA manager and the Nuclear Vice Frcsident used rubber stamps to stamp their names in the assigned spaces to denote their con-currence in all the sections of their QA manual dating back to 1977. The practice of using rubber stamps continued until the CECO audit in hovember 1988. The QA manager stated that he currently attests his signature with the date in the assigned columns to denote his concurrence or approval.
During the inspection, the team observeo that Fab tickets identifiea as Q-M-301-03 through 08 prepared for Dresden were approved by Impell on June 3, 1988.
Records indicate that ductwork fabricated to these drawings were shipped in August 1988. Mest of these components are reported to have been installed at Dresden.
Fab tickets Q-11 and 0-22 through 32, prepared for Qutd Cities, were approved by Impell on August 11, 1988.
Records indicate that ductwork and other components such as hangers fabricated to these drawings were shipped on Octcber 25, 1988. As of January 25, 1989, the ductwork has not been installed at Quad Cities. Approval of the Fab tickets prior to the commencement of fabrication meets the requirement of paragraph 0115-5 of Specification 0557-021-5-1 which states in part, 'After notifications of the award, the contractor shall furnish the 5
l
ORGANIZATION: TliE ROBERT IRSAY COMPANY SK0KIE, ILLINDIS 60076 REPORT INSPECTION N0.: 99900742/89-01 RESULTS:
PAGE 6 of 18 l
l drawings, data and documentation called for in the specification and Fonn S-1 and as specified herein." The preparation of the Fab tickets appears to comply with paragraph 7.12 of the RICO QA manual.
Paragraph 7.12 states in part, " Fab tickets are prepared l
and signed by the site draftsman and are reviewed by the Site General Foreman (SGF). The SGF will cocument the review by signing in the SGF block at issue and at each revision. When review or approval is required by the cortract, the Fab ticket is submitted using a Field Engineering itemorandum or letter of transmittal. Upon client approval, the SGF will sign the
' approved' space in the title block. Only ' approved' copies are to be usec for construction."
Though the Fab tickets for Dresden and Quad Cities generally complied with this requirement, the title blocks were different because they were prepared by different individuals at two site locations. The QA manager stated that in the future, he will ensure that the title block formats of the Fab tickets will be consistent. The inspectors were able to determine from the documents examined that fabrication of ductwork commenced af ter Impell's approval.
4.
Plant Tour The inspectors, accompanied by the QA manager, toured the plant to observe sheet metal cutting, welding of ducts, and storage.
Currently, except for an access door for Kewaunee nuclear power plant, all the work being performed was for commercial appli-cations. The inspectors observed that only gas metal arc welding was being utilized to weld ductwork.
a.
Observation of Kewaunee Access Door The inspectors observed one 24 by 30-inch HVAC access door fabricated to meet Fab ticket identified as "Q-Tag DCR 2259." The material used to manufacture the door was listed on the drawing. Two welders, who performed welding on the door, were identified on the Fab ticket. The inspectors examined the welds attaching the " Sash" locks to the access door frame and concurred with the RICO QC inspector that all welds were 1/2-inch long and 1/8-inch thick. The inspectors observed the following documents in the documentation package for the access door.
6
i ORGANIZATION: THE ROBERT IRSAY COMPANY SKOKIE, ILLIN0IS 60076 REPORT INSPECTION N0.: 99900742/89-01 RESULTS:
PAGE 7 of 18 l
(1) Outline drawing Q-Tag DCR 2259 approved by Flour Daniels, the architect-engineer for WPSC.
(2) Typical Certified Material Test Reports (CMTR) on the E-70S-3 weld wire (used in the fabrication of the access door) n. manufactured by Alloy Rod were provided by U.S. Welders, River Grove, Illinois.
RICO prepared a weld coupon with this wire and sent it to an indepen-dent testing laboratory who determined that the tensile strength of the specimen was 76,000 pounds per square inch-(psi); the minimum tensile strength of E-70S-3 is specified to be 70,000 psi. This matter is also discussed in paragraph 9a(6) of this report.
(3) WPS S-3-9 approved by WPSC on November 31, 1983 was used to fabricate the access door.
RIC0 stated that this was a repeat order. As such RICO utilized a WPS that was approved by WPSC in 1983.
(b) Review of the Implen:entation of Fab Tickets The inspectors reviewed all adverse findings relative to the use of a hardware ticket identified by CECO in their audit performed on December 7-8, 1988.
RICO is required to utilize a Fab ticket to fabricate access doors according to the QA program. This ticket has provisions to document material used in the manufacture and to provide traceability and to record inspections performed.
The access door is a component of the ductwork. During an audit, Ceco observed that RIC0 used a hardware ticket instead of a Fab ticket to n.anufacture the access coor.
A hardware ticket does not have the same provisions as a Fab ticket to list the material and thereby provide trace-ability of the material used in the manufacture of the com-ponent. The access door is only shown on the duct drawing and, therefore, was not listed separately as a component on the Fab ticket.
For example, drawing 03 Revision 1, dated August 1, 1986, which was approved by Impell on August 11, 1988, shows an 18-inch squate access door which is to be located in the field.
However, the door itself is not individually listed on the material to be used to fabricate the duct piece. Hardware ticket QC-H1, dated November 28, 1988, i
7 l
l
l ORGANIZATION: THE ROBERT IRSAY COMPANY SK0KIE, ILLINDIS 60076 REPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 8 of 18 was used to fabricate three of these access doors. Hardware, as referenced in RICO's duct brochure on page 17 Revision 1, was required to be used. A copy of this page was attached to the bardware ticket.
Corrective action taken by RICO to Ceco's adverse audit finding was to generate a Fab ticket, 03A, dated December 8, 1988, which was approved by Impell on January 11, 1989, incorporating all the details described on page 17 of the duct brochure. RICO scrapped the previously fabricated three access doors.
5.
Review of Control of Special Process The inspectors reviewed the preparation, control, ano qualifica-tien of the welders. At the RICO shop, only the Gas Metal Arc Welding (GMAC) process, which utilizes E-70S-3 type weld wire, is utilized to weld the ductwork.
WPS 3 is qualified for this process.
At the sites, Shielded Metal Arc Welding (SMAC) is used to weld structural steel and sheet metal. WPSs 1 and 9 have been qualified l
for these applications.
I WPS 1 was approved by Impell on May 28, 1988, and WPSs 3 and 9 were approved by Impell on March 25, 1988.
Impell's approval of the WPSs prior to the commencement of the job complied with paragraph 0108.5 of specification 0597-021-S-1, which states in part:
" Contractor shall submit written welding procedures for shop welding and field welding for approval prior to production welding.
Contractor shall also be responsible for the quali-fication of contractor's welders. All procedures and quali-fications shall be approved by the engineer and a copy of each kept on file at the construction site by the contractor."
During a site visit to Quad Cities, the inspectors determined that RICO utilizes CECO WPSs, to install duct hangers ard weld attachments to the ducts.
6.
Observation of RICO Activities at Quad Cities The NRC inspectors visited Quad Cities on January 25, 1989 to observe RICO's activities.
8 i
ORGANIZAT10N: THE ROBERT IRSAY COMPANY-SK0KIE, ILLINDIS 60076 REPORT INSPECTI0tl NO.: 99900742/89-01 RESULTS:
PAGE 9 of 18 a.
Observation of Storage of Ducts The inspectors visually inspected the duct pieces stored in the pump house of the Quad Cities nuclear power plant and concurred with CECO's finding that the spacing between the stitch welds attaching the stiffeners to the ducts were spaced more than 8 inches apart and were not in accor-l dance with the drawing on DB 10 prepared by RIC0 and approved by Impell. DB 10 specified 3/16-inch welds to be 2 inches i
long and 8 inches apart.
Individual Fab tickets reference DB 10 for the stitch weids. CECO generated Nonconformance Report (llCR) 17-88 on November 18, 1988 to indicate that the distance between the stitch welds attaching the stiffener angle were spaced further apart than eight inches and that the ducts, therefore, did not meet.the approved drawings.
The NCR also stated that the QC shop inspector and the shop welders did not follow design documents in the fabrication and inspection of ths~ ducts. Action required to correct the nonconformance was to prepare as-built cetails on the welds and submit them to Impell for review. CECO inspected all the ducts and provided details of "as-built" spacing of the welds to Impell.
Impell reviewed the "as-built" information and accepted the "as-is" welds on the ducts. The inspectors determined that Ceco took sirailar corrective action on ducts supplied to the Dresden plant.
b.
Review of Installation Procedures The inspectors determined that installation activities of the HVAC ducts were being performed to the requirements of Ceco's procedures instead of RICO procedures. The inspectors reviewed the following CECO procedures:
(1) Concrete Expansion Anchor (CEA) installation procedure QMMP 1505-1-52 Revision (Rev.) 1, dated January 1988, (2) CEA Inspection and Test Procedure QMMP 1505-2-51 Rev. 1, dated January 1988, (3) Studweld Procedure NSWP-G-03 Rev. 1, dated February 23, 1988, and 9
- " " ' ' ' " ' ~
ORGANIZATION: THE ROBERT IRSAY COMPANY j
SKOKIE, ILLIN0IS 60076 REPORT INSFECTION NO : 99900742/89-01 RESULTS:
PAGE 10 of 18 l
i (4) Studweld Inspection Procedure NSWP-G-03. Exhibit A.
The inspectors determined that the above procedures
)
adequately reflected the requirements to install ano inspect "Hilti-Quik" type concrete anchors and threaded Nelson studs which are required to install duct hangers.
c.
Observation of Partially Completed Hangers at Quad Cities The inspectors observed three welds identifieo as 0-22, Q-30, and Q-16 which were completed on three different hanger attachments at the titae of the NRC inspection. The inspectors visually inspected the velds and observed that the sizes and profiles of the welds met the drawing requirements. The J
welds were free from undercut, surface porosity and cracks.
CECO has authorized an independent test inspector to inspect RIC0's site work. These inspections had not been completed at the tine of the NRC inspection.
l 7.
Review of Completed Fab Tickets 1
The inspectors reviewed Fab tickets Q-4, Q-6, Q-7, Q-9, Q-10, Q-12,Q-13,Q-14,Q-16,Q-18,Q-20,Q-22,Q-24,Q-26,Q-28,and Q-30 and determined that the inspection of the welds were docu-mented as acceptable whereas they were unacceptable. Specifically, the 3/16-inch size welds attaching the stiffeners to the duct were required to be 2 inches long, spaced 8 inches apart. All the welds were 2 inches long but were spaced more than 8 inches apart. The spacing of the welds attaching the companion flanges to the ducts were acceptable. Documenting the inspection of unacceptable welds as acceptable is contrary to paragraph 11.4 of the RICO QA manual which states, in part:
" Craftsman performing fabrication work shall initial the appropriate box on the Fab ticket signifying satisfac-tory completion of the work and that it conforms to the procedure and drawing requirements.
... Production's properly initialed copy of the Fab ticket shall be presented to the Q.C. Technician at this time....
The Q.C. Technician will perform a visual inspection of the production iteni and verify acceptable completion cf work in accordance with the Fab ticket and duct brcchure...If the inspection shows all attributes to be acceptable, the Q.C. Technician will sign the Fab ticket and inspection report to signify acceptability."
10
ORGANIZATION: THE ROBERT.IRSAY COMPANY SK0KIE, ILLINDIS 60076 REPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 11 of 18 1
Contrary to the above, the Fab tickets indicate that the welds were acceptable, whereas, in fact, the spacing was incorrect.
The inspectors informed the QA manager that this was on item of nonconforniance, contrary to Criterion X of 10 CFR 50, Appendix B, and Section 11.4 of the RICO QAM manual.
(89-01-01) 8.
Review of the Control of Procured Items RICO purchases items consumed in the fabrication and installation of the ductwork from suppliers listed cn their " Approved Vendors List (AVL)." RICO also purchased items, such as dampers and
" Quiet-Duct Silencers," which are included in the scope of the HVAC system and listed in the purchase specification, and supplied them to the site. The RICO QA manual permits RICO to purchase those items from vendors not listed on the AVL if those items are listed in the scope of supply. Paragraph 5 of Procedure QC 1-5-1 Rev.1, dated January 20, 1988, approved by Impell t>n March 25, 1988, permits RICO to purchase safety-related material from vendor.s not listed on RICO's AVL, if the customer lists such material in the scope of supply of the purchase order (P0) and the vendors appear on either IMPELL's or CECO's AVL.
The inspectors reviewed tne following P0s prepared by RICO for the Dresden plant:
a.
P0 5875-010, dated April 4,1988, to Ruskin Manufacturing Company for the supply of three volume control dampers.
Compliance to 10 CFR 21 and 10 CFR 50, Appendix B was required.
b.
P0 5875-011, dated September 27, 1988, to Industrial Acoustics Company for the supply of two " Quiet-Duct Silencers."
c.
PO 5875-035, dated May 9, 1988, to Albany Steel & Brass Corporation (ASEC) for the supply of bolts, nuts and lock-washers.
Certificates of Conformance were required on all material supplied.
c.
P0 5875-014, dated March 29, 1988, to Rubatex Corporation for the supply of 1/4-inch by 2-inch R-45 backing rings.
Material certification that the gaskets meet the require-ments of ASTM _D1056-1978, RE-45-El was required.
I 11
d
'l l
ORGANIZATION: THE ROBERT IRSAY COMPANY SK0KIE, ILLIN0IS 60076 REPORT IMSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 12 of 16 e.
PO 5875-039, dated May 9, 1988, to ASBC for the supply of screws manufactured frora wire conforming to ASTM-A-548 and Zinc coated to conform to ASTM B-633, thickness SC2 Type 1, and f.
P0 5875-044, dated June 23, 1988, to ASBC for the supply of 2000 pan head metal screws.
All the requisitions, which are prepared prior to the issuance of a P0, were observed to be signed by representatives of QA, site quality control and RICO management. The P0s are printed by a computer, to reflect the quality requirements specified in the purchase requisition; however, in the case of items e and d above, the computer printout did not include the QA manager for concurrence. The RICO procurement staff informed the inspectors that there was a problem in the computer program and that they are currently working to debug it.
The inspector observed that, unlike the purchase requisitions, which are required to be identified as Q or non-Q, there is no similar requirement to identify a P0. The QA manager stated that he will consider the requirement to identify the P0 also as Q in the future.
9.
Review of Audits Performed on RICO The inspectors reviewed the followir,g audits performed on RICO.
a.
Commonwealth Edison Company Audit of RICO (December 7-8,1988)
Ceco performed an audit of RICO on December 7-8, 1988 with a team of three individuals. This audit resulted in 10 findings and the suspension of quality related activities for CECO jobs at RICO. The audit findings and the RIC0 responses are described in the following paragraphs:
(1) Three inspection findings were related to deficiencies in following the established QA program during the manufacture of three safety-related duct doors intended for the Quad Cities plant. These doors were observed during manufacturing as not having a Feb ticket and with no identification markings for traceability.
Both of these oraissions are contrary to the RIC0 QA manual and 12
ORGANIZATION: THE ROBERT IRSAY COMPANY SK0KIE, ILLIN0IS 60076 REPORT INSPECTION N0.: 99900742/89-01 RESULTS:
PAGE 13 of 18 l
approved RIC0 procecures (Section 6.2 Instructions, Procedures, and Drawings, Responsibilities).
The third finding resulted f rom lack of identification of the doors as nonconforming safety-related components or parts to prevent further processing or inadvertent use. The failure to identify a nonconforming part was contrary to Section 16.1 of the RICO QA roanual entitled
" Nonconforming Materials, Parts or Components, Scope."
The RICO resolution to these audit findings was to scrap the fabricated doors that were in question.
In addition, all personnel involved in the fabrication of a subsequent door for Kewaunce were reindoctrinated in the requirements for manufacture of safety-related components and parts. This resolution was considered satisfactory. During the NRC inspection, the inspectors reviewed traning documents that indicated that reindoc-trination classes were in fact conducted.
(2) Three other audit findings were related to the centrol of the quality assurance program at RICO.
Specifically the audit identified the lack of an annual review of the RICO QA program by corporate management, the 1&ck cf an indoctrination and training program for RICO personnel performing cuality activities, and internal audits being performed by personnel having direct responsibility for the areas being audited.
RICO responded to the first two of these findings by scheduling a canagement review of the QA program for June 1989 and a series of training sessions on various aspects of the QA manual and the quality control procedures.
In addition, a RICO commitment has been established to provide for indoctrination of shop personnel when personnel changes occur, procedures change, or new projects are initiated.
As to the finding related to inappropriate personnel performing internal audits, RICO performed an independent audit of the home office and shop on January 6,1989.
The audit was conducted by a QA technical representative from the RICO Dresden site office which identified cre l
13
ORGANIZATION: THE ROBERT IRSAY COMPANY SLOKIE, ILLINDIS 60076 REPORT INSPECTION N0.: 99900742/89-01 RESULTS:
PAGE 14 of 18
)
finding. The next scheduled internal audit is July i
1989. The inspectors observed a similar finding identified during a previous audit by CECO on March 30, 1987.
Specifically, the finding identified that internal audits were performed by the QA manager and, therefore, the audits were unacceptable ba ed on the requirements of the QA manual.
Notwithstanding, RICO I
performed the cuoit of June 13, 1988 with the same individual. The inspectors informed RICO that this l
did not indicate a responsiveness on the part of RICO to the findings noted in the Ceco audit of March 30, 1987.
(3) The validation of quality documents through the use of signature stamps instead of actual signatures was another finding in the CECO audit. The QA manager and i
Executive Vice President have been using signature stamps to approve quality documents since 1977. RICO stated that stamps were used because the assigned spaces were limited. As a result of the Ceco finding, RICO l
destroyed the signature stamps and is using original signatures to approve documents.
l (4) The RIC0 QA manual and procedures require that indi-viduals responsible for welding inspections (Q.C.
technicians as described in the procedures) must successfully complete an examination.
Contrary to this requirement, CECO observed that the Q.C. techni-cian involved in a safety-related project for the Quad Cities plant had not passed the welding inspection examination.
Eventhough the individual involved had been a properly certified inspector for previous l
projects, he had not been certifieo for the current
}
Quad Cities program. RICO administered the appropriate l
written test which the candidate successfully passed.
(5) One audit finding was related to the use of an unapproved vendor to calibrate four thermometers intended to check the temperature of weld rod holding ovens. Subsequently, RICO established that these thermometers had not been used in any safety-related work.
Subsequent to the CECO audit, RICO completed a 14
ORGANIZATION: THE ROBERT.IRSAY COMPANY SK0KIE, ILLIN0IS 60076 l
REPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 15 of 18 l
l survey of Pro-Quip, Inc., the thermometer vendor.
This audit was performed on January 13, 1989, and the results were reported as satisfactory.
(6) The last finding related to the lack of CMTRs for weld filter material delivered to the Quad Cities RICO site for use in safety-related work. Typical analyses results, rather than actual test results, were supplied by RIC0 and accepted by the RICO on-site receiving inspector. This is contrary to the Quad Cities HVAC specification 0597-023-5-1, Rev. 2 which requires actual CMTRs for Seismic Category I duct systems.
Nonconformance reports have been issued for the duct systems and the status is being reviewed.
This finding remains open; however, RICO has initiated an order for new weld materials with actual CMTRs.
RICO prepared and tested a weld coupon utilizing the E-705-3 Welding wire used in the fabrication of these ducts and deter-mined that the tensile strength exceeds the specified requirements.
Refer to paragraph 4a(2) for details, b.
CECO Audit: March 30, 1987 CECO performed an audit at RICO on March 30, 1987.
The audit team consisted of one member who identified two adverse findings.
One finding identified that the QA manager was functioning as a QC technician, without a current eye examination on file. The other identified that internal QA audits were perf ormed by personnel having direct responsibilities in the areas being audited. The example cited was internal audits performed by the QA manager.
Both of these findings were closed based on a written response from RICO to the audit.
In response to this adverse Ceco cucit findir.g, RICO made a commitment that future audits of areas within the direct responsibility of the QA manager will include another auditor. This commitment was documented in the RICO letter to CECO dated April 22, 1987. The internal aucit of Jur.e 13, 1988 was performed by the QA manager and directly negated the RICO ccmraitment to CECO. Furthermore, it inoicates a 1cck of responsiveness by RICO to take corrective actions tc prevent recurrence of nonconformances. As a result nonconformance (89-01-02) was identified in this area.
15
ORGANIZATION: THE ROBERT IRSAY COMPAliY j
SKOKIE, ILLIN0IS 6C076 REFORT INSPECTION NO.:
99900742/89-01 RESULTS:
PAGE 16 of 18 c.
Bechtel Power Corporation Audit: January 26 - April 13, 1988 Bechtel Power Corporation (BPC) conducted a " Full Scope and Progressive Audit" at RICO over the period January 26 -
April 13, 1068. The audit team consisted of one individual and no noncompliance were noted.
BPC described the audit l
results as satisfactory.
d.
Wisconsin Public Service Corporation (WPSC) Audit:
December 9-10, 1987 WPSC, owner of the Kewaunee nuclear power plant, performed an I
audit of RICO on December 9-10, 1987. This audit was performed by Gasser Associates for WPSC and was completed by onc individual. The results indicate that RICO's QA program is considered satisfactory and no open items or noncon-formances were identified.
e.
Wolf Creek Audit: Cecember 29, 1986 Wolf Creek Nuclear Operating Company (WCNOC), cwners of the Wolf Creek nuclear power plant, performed an aedit at RICO l
on December 29, 1986 with a team of three individuals. The audit results included one area of concern related to the approval of a part substitution made by RICO. This concern was subsequently closed and audit results were considered satisfactory.
f.
Review of Audits Performed of RIC0 On-Site Organizations RICO currently has on-site organizations at the Dresden I
and Quad Cities plar.ts.
CECO has performed audits at both of these sites. The results of the review of these audit reports are described below:
(1) Dresden RICO site: Audits were performed on the RICO site organization at Dresden on August 18, 1988 and October 28, 1988.
The first audit (Report Number QAA 12-88-43) was performed by three auditors and resulted in three findings.
These findings were related to the calibration of torque wrenches and the imposition of 10 CFR 21 requirements on instrument calibration vendors. The findings were satisfactorily resolved by 16
ORGANIZATION: THE ROBERT IRSAY COMPANY SKOKIE, ILLIN0IS 60076 REPORT INSPECTION NO.: 99900742/89-01 RESULTS:
PAGE 17 of 18 revising RICO procedures. One observation and two open items were also identified during the audit but did not require RICO actions.
The second audit (Report QAA 12-88-46) was performed by one individual who identified two observations which did not require R100 action.
(2) Quad Cities RICO site: Two audits were completed at this site. The first audit report, QAA 04-88-53, performed on August 22-26, 1988, produced a finding related to the delivery of safety-related equipment without documentation. The receipt inspection by Ceco at the site identified that the required certifications were not available for the weld filler wire that was delivered to the site. The RICO response indicated that this occurrence was an errcr and appropriate action would be taken.
The second RICO site audit was performed from October 31 through November 4, 1988. The audit report, QAA 04-88-61 identifico one findir.g related to the delivery of safety-related items for installation without the required quality documentation.
It should be noted that this finding is similar to the finding of audit QAA 04-88-53.
g.
Review of the RICO Quality Assurance Manual (QAM)
The inspectors reviewed Sections 16, 17 and 19 of the RICO QA manual in view of the occurrence of repeated audit findings
- i. gainst the RICO QA program. The inspectors determined that statements in Sections 16,17 and 19 do not compiment each other.
Section 19 does not address adverse audit findings identified by RICO customers.
Hence, the adverse aucit findings are not treated as nonconforming conditions adverse to quality in Section 16. Therefore, corrective action, to resolve the nonconforming conditions, is not described in Section 17.
Consequently, a procedure was not developed to describe actions to be taken to correct adverse audit findings to preclude repetition.
RICO acknowledged this deficiency and stated that the program will be revised to correct this inadequacy. This is ariother exanple that contrit uted to Nonconformance 89-01-02.
17
ORGANIZATION: THE ROBERT IRSAY COMPANY SK0KlE, ILLINDIS C0076 REPORT INSPECTION NO. :. 99900742/89-01 RESULTS:
PAGE 18 of 18 i
F.
Persons Contacted During the exit interviews, the inspectors met with the following indi--
viduals at The Robert Irsay Company to discuss the scope and findings of the inspections.
j 1
The Robert Irsay Company, Skokie, Illinois I
Skokie, Illinois Of fice C. James Executive Vice President R. Kowalek Manager, Quality Assurance L. Beyski Quality Control Technician P. A. Capasse Quality Control Technician C. R. Sjoberg Shop Superintendent J. Fischer Project Manager R. J. Milfried Shop General Foreman M. E. Marbach Welding Foreman D. Stapleton Purchasing Agent D. J. Behls ProjectIlanager i
R. Peulsen General Superintendent I
Quad Cities Site Office l
F. Damon Project Superintendent j
R. Adams Quality Control Technician Commonwealth Edison Company - Quad Cities Site Office
]
D. Kunzeman Quality Assurance Engineer J. A. Horn Project Engineer l
l 18
ORGANIZATION: SQUARE D COMPANY CEDAR RAPIDS, IOWA 52404 REPORT INSPECTION INSPECTION NO.: 99901146/89-01 DATE: 3/27
,3/30/89 ON-SITE H0tfRS-4A CORRESPONDENCE ADDRESS: Square D Company Barbara Sines, Plant Manager 3700 6th Street South West Cedar Rapids, Iowa 52404 ORGANIZATIONAL CONTACT: Mr. M. Douglas, QC Manager TELEPHONE NUMBER:
319-365 4631 l
NUCLEAR INDUSTRY ACTIVITY: Molded case circuit breakers ASSIGNED INSPECTOR:
K. R. Naidu, Reactor Inspection Section No.1 Date l
(RIS-1),VIB,DRIS,NRR OTHER INSPECTOR (S):
H. M. Wescott, Special Projects Section, VIB, DRIS, NRR I
APPROVED BY:
E. T. Baker, Chief, RIS-1, Vendor Inspection Branch, Date ORIS, NRR INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21, 10 CFR 50 Appendix B B.
SCOPE:
Review the implementation of the quality assurance program in seiected areas; observed the manufacture and testing of circuit breakers; observed rated short circuit tests performeo on a refurbished and a normal molded case circuit breaker.
FLANT SITE APPLICABILITY:
Potentially all reactor sites.
19
F ORGANIZATION: SQUARE D COMPANY CEDAR RAPIDS, IOWA -52404
=
REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 2 of 9 i
A.
VIOLATIONS:
None B.
NONCONFORMANCES:
I None C..
STATUS OF PREVIOUS INSPECTION FINDINGS:
.Two unresolved items pertaining to the Square D (SD), Cedar Rapids, Iowa, plant were identified during a routine inspection at the SD Peru, Indiana, plant. These two unresolved items are documented in NRC Inspection Report No. 99900367/88-01.
1 These items could not be resolved in a timely manner prior to the con-cluvion of the inspection and remain open.
D.
OTHER FINDINGS AND COMMENTS:
1.
Background Information Commercial grade molded case circuit breakers'(CBs) between the ranges of 3 amperes (A) to 4000 A are manufactured at the Cedar Rapids plant under a quality assurance program compatible in many aspects with the 10 CFR 50 Appendix B requirements.. The CBs are furnished to the SD plant located in Peru, Indiana, where the CBs are dedicated for Class IE applications.
SD, Peru, also assembles motor control centers and furnishes them as Class IE equipment.
Spare CBs furnished by SD, Cedar Rapids are dedicated at the SD, Peru facility and supplied as Class IE equipment. To date, all purchase orders for spare CBs have been issued to SD.
Peru, who in turn obtained the CBs as commercial grade items with certificates of conformance from SD, Cedar Rapids. Other SD facilities manufacturing components utilized in nuclear power plants are:
SD Monroe, North Carolina: Transformers up to 5000 kVA with up to 34.5 KV maximum primary voltage SD Raleigh, North Carolina:
Electrical contactors and motor starters l
20 E___________
i
ORGANIZATION:. SQUARE D COMPANY CEDAR RAPIDS, IOWA 52404 REPORT INSPECTION
.NO.:
99901146/89-01 RESULTS:
PAGE 3 of 9 SD Raleigh, North Carolina:
Electrica' relays SD Ashville, North Carolina:
Electrical. relays l
The SD Cedar Rapids, Iowa, plant utilizes approximately 26,000 square feet and employes 800 persons. This facility has its own electrical generator to produce the necessary voltage and current to conduct short circuit' tests on low and medium voltage CBs.
l 2.
Plant Tour The inspectors, accompanied by SD personnel, toured the manufac-turing facility and observed the following; a.
In-process inspections were conducted by individuals manu-facturing components.
Procedures, with acceptance criteria, were available at each workstation, b.
Every CB was subjected to final tests.
c.
Materials received from vendors were properly identified and the status of receipt inspections were readily discernable.
d.
All items stored were adequately identified.
3.
Review of Control of Purchased Material Material supplied by vendors receive a " transaction" number upon receipt. The transaction number is the link to trace all the subsequent relevant records. The inspectors observed that all r,aterials at the receiving area were identified with either transaction numbers, receipt inspection reports or red tags denoting incomplete information to perform receipt inspection.
The inspectors noted the relevant information on the following components and subsequently reviewed the relevant documents.
d.
SD Purchase Order (P0) 6002279, dated January 31, 1989, to Kreider Corporation, Springfield, Ohio for the supply of switch actuators identified as Part No 48117-096-04, Transaction No., 9081139. The items ha^ been inspected and determined acceptable, b.
SD P0 600E408, dateo February 1,1989, te Mohcwk Sprines, Shiller Park, Illinois, for the supply of silver springs to 21
ORGANIZATION: SQUARE D COMPANY CEDAR RAPIDS, IOWA 52404 REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 4 of 9 Drawing No. 48030-314-04.
No problems were identified on these 4
springs.
l l
c.
SD PO 6001732, dated January 19, 1989, to American Coil l
Spring Company, Muskegon, Michigan, for the supply of trip lever springs to Drawing No. 48030-261-01, Revision ECW 234.
d.
SD PO 6097227, dated July 10, 1988, to Sons Tool & Engineering Company, Incorporated, Woodville, Wisconsin, for the supply of lower links to Drawing No. 48161-032-02-04.
e.
SD P0 6003139 dated February 15, 1989, to Arden Industrial Products, Saint Paul, Minnesota, for the supply of inserts to Drawing No. 29407-00173, Revision 278. This material was initially identified with Transaction Nc. 9081126 on March 22, 1989.
Receipt inspection identified that this material did not conform to Drawing No. 48030-314-04.
Subsequent discussions and inspections conducted by the assigned engineer confirmed that the parts were to Drawing No. 29407-00173.
The transaction tag was changed from 9081126 to 9087701 on March 28, 1989. The error was corrected electronically on the computer with the consent of the engineer and purchasing.
f, SD P0 6001573, dated January 17, 1989, to Dayton Rogers Manufacturing, Minneapolis, Minnesota, for the supply of 100 magnet slides to Drawing No. 48131-112-02-Y, Revision E718.
One hundred thirty-two pieces were received on March 7, 1989. Receipt inspection observed that all the 132 pieces had dimensional problems and the parts were not formed properly. The receiving inspection report, for Transaction No. 9066057, with the adverse inspection findings, was
- forwarded to the cognizant engineer responsible for that part. After an evaluation, the cognizant engineer determined that the parts were usable as-is.
It was also recommended that the vendor be notified of the deficiencies identified during the receipt, along with samples of the parts. SC notified the vendor on March 15, 1989, to correct the deficiencies before shipping any future orders.
The inspectors determined that the approved vendors are incorporated in the computer program to enable purchasing to buy only from vendors previously approved.
However, if interial is purchased f rom vendors 22
l ORGANIZATION: SQUARE D COMPANY CEDAR RAPIDS, 10WA 52404 REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 5 of 9 not identified in the computer program, then, first piece inspection is mandatory. The issuance of the received material is controlled until such time that the assigned engineer is satisfied that the supplied material is acceptable. The inspectors determined that the above activities were in compliance with Standard Practice Bulletin (SPB) 317 titled, " Vendor Selection for Productive Material," dated May 5, 1988, which establishes the guidelines to be used for selecting vendors and SPB 315 titled, " Issuance of Purchase Orders," dated May 4, 1988, which defines the requirements necessary for issuance of a P0.
4.
Observation of In-Process Inspections The inspectors, accompanied by SD personnel, observed the manu-facture of components required to assemble FA type molded case CBs. Operators performing the work periodically inspected the work to procedures, which cefined acceptance criteria. The applicable procedure was posted at the workstation. The inspectors examined the components and the inspections being performed on the components at the following workstations:
a.
Contact being brazed to terminal identified as Part No.
48124-331.57. The requirement at this station was to determine the acceptability of the braze attaching the contact to the terminal.
To accomplish this, five pieces were inspected every hour for the following attributes:
(1) Verify that the solder flow was adequate on three sides.
(2) The contact is brazed straight on the terminal.
(3) Go-no-go check to verify that the minimum contact height "
.140 millimeter, b.
Cradle assemuly being riveted to the mechanical housing.
Af ter riveting the cradle assembly to the mechanical housing the following attributes were verified:
(1) Check the gr%se on the subassembly.
(2) Proper roll on the rivets.
(3)
Inspect the left housing for cut-off area.
23
ORGANIZATION: SQUARE D COMPANY CEDAR RAPIDS, IOWA 52404 REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 6 of 9 c.
Bi-metal / terminal assembly identified as Part No. 48124-356-50-54. At this operation, after the bi-metal is assembled to the terminal, the fonued heights of the bi-4 metal on three specimens are measured with a gauge to determine that the formed heights are within the acceptable l
values stated on the procedure.
The procedure specifies the l
values for a variety of assemblies depending on the CB l
rating.
d.
The magnetic trip is calibrated on each pole of the CB and adjusted during a trip-trip-hold-trip-bold-trip cycle of operation.
The thermal overload. trip on each CB is calibrated by an e.
l automated operation. The machine is programmed to test the CB and automatically adjust the calibration in two attempts.
If the calibration cannot be adjusted to conform to the acceptable value in two attempts, then the CB is diverted to i
a different station.
At this station, the thermal overload is calibrated manually, left for a specific period of~ time j
to cool the bi-metallic strip, and after the elapse of a predetermined time, the trip setting is finally verified.
The inspectors cbserved that the results of the in-process inspections were being documented on inspection reports.
j SD representatives stated that the in-process reports are collected and stored for at least six months.
5.
Observations of Short Circuit Tests On March 29, 1989, SD performed rated short circuit tests on two three-phase KHL 36225 type moldea case CBs.
One was a new one from the production lot. The rear cover on the second CB was replaced with a counterfeit cover to simulate a refurbished one.
When subjected to 25,000 A, the new one tripped and was subsequently examined and determined operable.
The tampered one experienced extensive damage. The line side terminal leads melted.
It was postulated that the short circuit current tripped the CB.
However, during the short circuit interruption, the ionized air caused by the high current, instead of escaping l
through the normal channels provided in the genuine CB, escaped through the top, causing a phase to phase short resulting in i
the destruction of the line side cable terminals of the CB.
l 24 i
1 i
ORGANIZATION:
SQUARE D COMPANY CEDAR PAPIDS, IOWA 52404 REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 7 of 9 6.
Review of Control of Design Changes The control of revisions to drawings, distribution of revised drawings and removing obsolete drawings from use are addressed in Paragraph 3.4.5 of the SD QA manual. Paragraph 3.4.5 states,
" Changes to previously verified designs shall require verifica-l l
tions, including evaluations of the effects of those changes on other modules or components of the overall equipment." This procedure is complemented by an Engineering Procedure EP-2 titled, " Report Procedure for Design Documents," dated May 1987, which states, in part, in paragraph IIB, "The Existing Product Engineer shall be responsible for changes wnich affect the customer or other plants, such as, resciution of performance problems, product upgrades and design enhancements." The Engineering Change Notice (ECN)gs were revised after an inspectors observed that drawin was initiated describing the change to that component. The ECN is circulated to the cognizant engineer for review and approval.
In the interim, while the review process is in progress, the original of the drawing is annotated to preclude inadvertent use of the drawing while the ECN was being reviewed. The inspectors selected five drawings, examined the control of ECNs and determined the following:
a.
Revision H, dated October 10, 1988, to Drawing No. 48124-120 was accomplished with ECtl F711. ECN F711, dated January 11, 1989, was initiated to change the load end venting of certain FA type CBs by using slotted load barriers.
b.
Revision D, dated May 4, 1988, to Drawing NO. A48124 - 120 was accomplished with ECN U288. ECN U288 was initiated on April 13, 1988, to provide tolerances te the length of the line end barrier.
c.
Revision C, dated November 11, 1908, to Drawing No. A8124-237 was accomplished with ECN F726, dated Dececher 20, 1988. ECN F726 approved gold plated wire and switch assemblies, d.
Revision F, dated December 19, 1988, to Drawing No. A48117-024 was accomplished with ECN F732, dated February 3,1989.
ECN F733 increased the tolerance on the width of the handle shield for certain KA type CBs.
25
t ORGANIZATION:
SQUARE D COMPANY CEDAR RAPIDS, IOWA 52404 REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 8 of 9 e.
Revision A, dated December 19, 1988, to Drawing No. A4118-108 was accomplished with ECN F733, dated February 3, 1989. The ECN modified the drawings of the inner and outer visiblade i
handle shields so that handles intended for KCL and FA type CBs could be manufactured by using the same stamping, i
7.
Review of Calibration System 1
The inspectors reviewed Square D QA Manual Criterion XII, i
" Control of Measuring and Test Equipment" dated May 16, 1978.
Review of calibration certificates establ1shed that standards used for calibration of electrical and mechanical instruments were traceable to the National Bureau of Standards.
It was noted that the certification for the standard used to calibrate electrical meters ~ (Fluke) did not have the calibration data sheets to substantiate the certificate.
It is the inspectors j
understanding that the data sheets would be requested.
j l
During a tour of the f acility the inspector noted that two " mag l
boards" identified as FE No. 6423 and FE No. 6522, used to verify breaker trip times on overload, had not been calibrated before their due dates. The calibration card for FE No. 6423 indicated that the last calibration was performed February 6, 1987, and was due for calibration in August 1988, which had not
(
been performed. The calibration card and records could not be located for FE No. 6522. Calibration of the two mag boards were performed during this inspection and determined to be within tolerance.
No discrepancies were identified.
8.
Review of Audits The inspectors reviewed the corporate QA audit for 1988. Several findings were documented pertaining to calibration and storing of materials.
Response to the findings indicated that action was being taken to correct the findings. Additionally, the inspectors reviewed the internal audit schedule, preparation of audit forms, conduct of audit, and review of the 1987 in-house audits which appeared to be satisfactory.
l There was one customer audit of the SD facility performed by Virginia Electric Power Company approving the QA program by letter dated March 17, 1987. Normally customer audits are performed at SD's facility in Peru, Indiana.
I 26
ORGANIZATION: SQUARE D COMPANY CEDAR RAPIDS, IOWA 52404 REPORT INSPECTION NO.: 99901146/89-01 RESULTS:
PAGE 9 of 9 l
The inspector reviewed the purchasing department " Vendor i
Evaluation / Certification Program" procedure describina the various ratings applied to vendors prior to becoming a s.rtified vendor. The inspector also reviewed one " Vendor Certifici ion /
t Evaluation Report" of Data Metalcraft, Incorporated, dated, February 1989 and performed a review of the approved supplier list printout. !!o discrepancies were identified.
E.
EXIT MEETING:
The inspectors raet with individuals identified under persons contacted, explaintd the scope and purpose of the inspection and discussed the inspection findings.
F.
PERSONS CONTACTED:
G. O. Lofgren Corporate Quality Manager
- B. Sines Plant Manager
- M. Douglas Quality Manager L. Serbousek Marketing Manager
- G. Gregory Chief Engineer
- P.
Zimmerman Customer Service Supervisor
- P. Rainbow Custoner Service
- K.
Chown Manufacturing Manager K. Slagle Quality Engineer D. Smith Quality Assurance Technician
- Denotes those individuals who attended the exit interview on March 30, 1989.
l 27
1
- ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTI0tt INSPECTIO!1 NO.: 59900225/89-01 DATE:
February 6-10, 1989 ON-SITE HOURS: 74 i
CORRESPONDENCE ADDRESS:
Dr. Peter F. McCrea, Vice President, Research, Design, and Quality Assurance.
The Foxboro Company Mail Stop No-2B Foxboro, Massachusetts 02035-2099 l
ORGANIZATICf;AL CONTACT:
S. Hasan Razvi, Corporate Quality Assurance Manager TELEPHONE NUMBER:
508-543-8750 NUCLEAR IriDUSTRY ACTIVITY:
Pressure and differential pressure transmitters, level ard flow transmitters, monitoring and actuating system panels.
0 A
~
ASSIGNED INSPECTOR:
K. R. Naidu, Reactive Inspection Section No. 1, Date (RIS-1)
OTHERINSPECTOR(S):
T. J. Keck, Brookhave National Laboratories
/"- d) '
IA 7
APPROVED BY: /E. T. Baker, Chief, RIS-1, Vendor Inspection branch, Dhte DRIS, NRR ItiSPECTION BASES AND SCOPE:
A.
BASES: 10 CFR Part 21, 10 CFR 50, Appendix B.
B.
SCOPE: Reviewed the problems with certain components received at RTTTstone 2 nuclear power plant; reviewed the implementation of the quality assurance program in selected areas; observed the final assembly and testing of one transmitter; reviewed the status of findings identi-fied in NRC Inspection Report 99900225/85-01.
PLANT SITE APPLICABILITY: Millstone 2 (50-336), San Onofre (50-361;362),
DC Cook (50-315;316).
l I
l 29
q GXGANIZATION: THE FOXBORO COMPANY FOXBORD, MASSACHUSETTS REPORT INSPECTION N0.: 99900225/89-01 RESULTS:
PAGE 2 of 13 A.
VIOLATIONS:
No viol" bns were identified during this inspection.
B.
NONCONFORMANCES:
Contrary to Criterion V, of Appendix B to 10 CFR 50, " Instructions, Procedures, and Drawir.gs," and paragraph 4.2 of The Foxboro Ccmpany l
(lFC) Corporate Quality Assurance (QA) Procedure 3.18.3, Revision C, dated October 27, 1986, the Nuclear Product Safety Subcommittee (NPSS) was not convened to evaluate the problems reported in repair order 88R-94760 concerning the evaluation of two N-2AX+SLt1 type safety-l~
related printed circuit boards (PCBs). The PCBs, which had been I
l-recently furnished to Millstone 2 as safety-related components, were determined to be inoperable during receipt inspections at Millstone 2.
C.
UNRESOLVED ITEMS:
No unresolved itens were identified during this inspection.
D.
STATUS OF PREVIOUS IISPECTION FINDINGS:
1.
(Closed) Violation 85-01-01 The violation identified that TFC failed to evaluate a problem identified at San Onofre 1 in 1978 concerning the degradation of electrical conductor insulation of "E-Line" ccotrollers and TFC failed to notify either the Nuclear Regulatory Com.ission (tlP,C) or the nuclear power plant customers as required by 10 CFR Part
- 21. During this inspection, the inspectors determinec that the implementation of the steps taken to correct the violation, as outlined in TFC's letters dated May 28, 1986 and June 4, 1986, were adequate.
2.
(Closed) Violation 85-01-02 The violatiori identified that TFC's procedure for 10 CFR Part P1 evaluations was inadequate. Six instances where TFC did not perform deportability evaluations were provided. The inspectors determined that TFC established Procedure 3.18.3 to analyze product defects to determine if the perceived problems were generic. Copies of the letters to their customers on failures consicered generic were made available for review.
30
i ORGANIZATION: THE FOXBOR0 COMPAhY FOXBOR0,liASSACHUSETTS
' REPORT INSPECTION H0.: 99900225/G9-01 RESULTS:
PAGE 3 of 13 Additionally, NPSS reviewed all the failure analyses reports generated during 1978 to 1988 and determined that none of the component failures were considered reportable according to 10 CFR Part 21 requirements. The NRC inspector concurs with the TFC conclusion.
3.
(Closed) Nonconformance 85-01-03 The nonconformance identified that TFC did not provide indoctri-nation and training programs for engineering, design, testing, corporate quality assurance, customer service, or management personnel. The inspectors reviewed 16 randomly selected indoc-trination and training ccurses scheduled and perforined in 1988.
No discrepancies were observed.
4.
(Closed) Nonconformance 85-01-04 This nonconformance related to an inadequate procedure to notify the NPSS of cenditions adverse to cuality. The inspectors reviewed the current procedure and determined the procedure to be adequate.
5.
(Closed) Nonconformance 85-01-05 The nonconformance identified that an outside calibration lab-oratory (ESSCo) was listed on the TFC approved Vendors List without any documented audit results. The inspectors reviewed the audit performed on ESSCo on June 16, 1986.
No adverse observations were identified.
ESSCO calibrates the prime stan-dards used by TFC to calibrate instruments in the Highland plant.
6.
(Closed) Nonconformance 85-01-06 The nonconformance identified that 2 of the 18 instruments sampled had labels to indicate that the calibration was overdue.
During the plant tours of the Heponset and Highland plants, 53 instruments used for testing and calibration were checked for calibration due dates.
No instrument was observed overdue for calibration. Two calibration standards located in the Neponset plant quality control test laboratory were selected and the calibration records were traced to the primary standards used in the Corporate Calibration Laboratory. The calibration records for the primary standards, which are cnlibrated by an outside 31
ORGANIZATION: THE FOXBOR0 COMPANY FOXB0RO, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS:
PAGE 4 of 13 calibration laboratory, were reviewed. The records included a statement that the calibration standards were traceab*.e to the l
standards located at the National Bureau of Standards.
7.
(Closed) Nonconformance 85-01-07 The nonconformance identified that internal audits were not performed quarterly for all stages of the manufacturing cycles.
l The inspectors reviewed the 1988 Highland Plant audit schedule.
Forty-four of the 45 audits scheduled covering all stages of manufacturing cycles were completed. One scheduled audit was cancelled.
E.
INSPECTION FINDINGS AND OTHER C0l!MENTS:
1 1.
Review of TFC Repair Program The inspectors reviewed the TFC repair program to determine the circumstances under which two of the four N-2AX+SLH pressure signal limiter printed circuit boards supplied to Northeast Nuclear Energy Center (NNEC), the owners of Millstone 2 nuclear power station, failed to perform during receipt inspections at the site.
Furthermore, NNEC identified considerable difficulty in sliding the PCBs into their frames, identified as TFC part number N-2AP. The pressure si the narrow range (0-1600 psig)gnal limiter limits the signal to pressurizer level transmitter, which is normally overranged during power operations. The information regarding the defective PCBs was obtained from IIRC Inspection Report 50-336/88-24, issued by NRC Region I office, documenting the results of the resident inspector's inspection of Millstone Unit 2 from October 13 through November 23, 1988.
NNEC purchase order (PO) 913894 to TFC included the supply of four N-2AX+SLM type signal limiter PCBs and four N-2AP type PCB holders.
These items were supplied to NNEC in August 1988 with a certificate of conformance, dated August 23, 1988, certifying that the items comply with the P0 requirements and that the components were manufactured with the same materials and processes as those qualified for Class IE service as documented in TFC Qualification Report Q0AAB51, Revision A.
Two of the four PCBs failed performance tests.
All four of the PCBs were diffficult to insert into the PCB holders.
NNEC returned the two defective PCBs to NNEC.
Repair documents indicate that or.e PCB had a short circuit and the other had a break in the foil on the PCB.
32 4
ORGANIZAT10N: THE FOXBOR0 COMPANY FOXBORD, MASSACHUSETTS REF(T INSPECTION NO.
99900225/89-01 RESULTS:
PAGE 5 of 13 The inspectors visited the Highland plant where these components are manufactured. The inspectors obtained a PCB and a PCB holder from stock and attempted to insert the PCB into the holder.
Considerable difficulty was experienced during insertion, due to a small 90-degree step where the PCB is guiced into the slot of the PCB holder.
Specifically, the problem was in the molded 30-pin connector identified as part number 8 on the assembly drawing NO300FZ, Revision R.
Drawing C0154BS, Revision J, depicting the detail of part number 8 (connector) indicates a taper instead of a step. The inspectors discussed this subject with the cognizant individuals in the molding department, inspected the die used to mold the connector and determined that the problem was apparently caused by the die. TFC took corrective action by preparing Tool Order 120212-010 to correct the step in both cavities to provide the taper in the die.
The inspectors determined that the PCB holder problem had not been identified previously because these PCB holders are assembled in panels manufactured by TFC. The problem arises only when spare PCB holders are purchased to extend the capacity cf the existing panels or replace individual PCB holders. The NRC is not asare of similar problems reported by any other nuclear power plant.
The inspectors observed that TFC did not convene the Nuclear Product Safety Subcommittee to evaluate the problems identified on the repair order (88R-94760) for the signal limiter PCBs, as required by Corporate QA procedure 3.18.3.
The inspectors informed the TFC QA Manager that the failure to follow Procedure 3.18.3 is contrary to Criterion V of 10 CFR 50, Appendix B and is considered a nonconformance.
(89-01-01)
The inspectors determined from discussions with cognizant TFC individuals familiar with the manufacture of the signal limiter PCBs that the terminals (tabs) of the potentiometers are required l
to be bent at a 90-degree angle after solder connections are completed.
If the potentiometer tabs are not bent, the PCB holders cannot accommodate the PCB because of the extra height.
The inspectors determined that test technicians are required to use Procedure 14400KF, Revision C to test the type signal limiters. TFC stated that the signal limiters supplied to NNEC were tested by a temporary trainee. The instructions to assemble the signal limiter PCBs have been subsequently revised to 33
' ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS:
PAGE 6 of 13 include a step which requires the potentiometer tabs to be bent at a 90-degree angle.
2.
Control of Design Drawings All the drawings related to components used to assemble nuclear safety-related instruments are stamped " Nuclear Safety Related."
Whenever such a drawing is to be revised, the drawing is accom-panied by a e Appendix &.parate sheet of paper identified as the Revision The RA is initiated by the cognizant engineer describing W change and is approved by his supervisor. The drawing and the RA are then forwarded to the Corporate Drawing Control Department who in turn sends it to Corporate Quality Assurance (CQA) to concur with the design change if the change does not affect the previous qualification of the equipment.
Paragraph 2.2.5 of the procedure for Corporate Engineering Standard (CES) 280:5q, Revision P, dated July 5, 1988, entitled,
" Revision Control Including Certifica Products," describes this process.
The inspectors reviewed the ras for drawings B0134MA, Revision B; C0131HN, Revision C; D0126VA, Revision T; and N0302MA, Revision C and determined that a CQA representative approved the change prior to final issue.
3.
Review of the Processing of Purchase Orders a.
Procedure for Processing The inspectors reviewed the processing of P0s issued by utilities for safety-related applications.
IFC personnel stated that all P0s are entered at the local TFC sales office and subsequently electronically transmitted to the pre-order entry office loc-ated at Robinson Hill, Foxboro. The order is stamped " Nuclear" to alert other offices that the component is intended for use in a nuclear power plant and is forwarded to huclear Power Engineering (NPE). MPE prepares a folder for the order, identi-fies the specific documentation to be supplied with the com-ponent such as (1) calibration, (2) nuclear grade cleanliness certificate, (3) hydrostatic test, and (4) certificate cf conformance (C0C). A " Manufacturing Production Sheet," which goes to the appropriate plant, is prep 7 red and stamped
" nuclear." A Repair Purchase Order (RFO) is prepared to repair safety-related items. The RP0 is also stamped " nuclear."
f 34
l ORGANIZATION: THE FOXBORO COMPANY FOXBORD, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS:
PAGE 7 of 13
/
The item is sent to the clean room where all the safety-related instruments are assembled. The instrument to be repaired is disassembled, tested and the cause of failure is determined.
NPE conveys the cause of the malfunction and the estimated I
cost to repair, to the customer and obtains his consent prior to performing the repair. NPE prepares the list of documents required and sends the RP0 to the clean room to get the instru-ment repaired.
TFC Engineering Operating Procedures (E0P) describing the above steps were available for review.
I b.
Review of the Implementation of E0Ps.
The inspectors reviewed the TFC folders for the following RP0 and P0s:
(1) American Electric Power Service Corporation issued PO 05354-041-8X, dated August 25, 1988, for the supply of one N-E13DH-H1M2-B type differential pressure transmitter, calibrated for the range 0-150 inches of water, with a C0C stating that the component is identical to that tested in reports Q0AA C10 & QCAACII/Wyle Test Report 45592-4/QA-N.
i (2) Southern California Edison Company (SCE) issued PO 6W128002, dated December 6, 1988, to TFC to repair a N-E13DM-IIM2J type differential pressure transmitter with serial number 5147469.
SCE stated in part that "the transmitter cannot be statically aligned with specification."
Implementation of the TFC quality assurance program was required.
SCE requested TFC to supply a C0C and a failure analysis report with the repaired transmitter.
(3) Northeast Nuclear Energy Company issued P0 913894, dated September 9, 1988, to repair two N-2AX+SLM type PCBs.
The inspectors determined that the E0Ps were complied with during the repair and manufacturing operations.
35
ORGANIZATION: THE FOXBORO COMPANY FOXBORO, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS:
PAGE 8 of 13 4.
Plant Tours During the inspection period, the inspectors, accompanied by TFC personnel, toured the plants located at Neponset, Highland, and Cocassett and observed various activities in progress.
a.
Neponset Plant The pressure, differential pressure, level, and flow trans-mitters and indicating type instruments are assembled in this plant. The hardware components such as pressure bcundary covers, force motor assembly parts, and plastic molded parts are manufactured in this plant. Other com-ponents, such as electronic PCBs manufactured at other TFC locations, are shipped to this plant for the final assembly i
of the transmitters.
The inspectors observed that in-process inspections were being performed at various locations where parts were being finished. A computer list provides information on the location of each purchased part and the number of items held in inventory in the warehouse.
b.
Highland Plant Electronic subassemblies such as amplifier boards and other PCBs are manufactured at this plant. A computer list was available at this location which provided information on the location and number of items available in inventory of purchased items, as well as finished components, such as, PCDs and PCB holders. The inspectors used this computer list to locate potentiometers installed in N-2AX+SLM type PCBs, the PCBs, and N-2AP type PCB holders.
c.
Cocassett Plant This plant manufactures panels to mer.itor the operation of various systems in nuclear power plants.
Components manu-factured at the Neponset, Highland, and other locations are used in the assembly of the panels. " Spec 200 Micro" panels for use in safety systems at the Connecticut Yankee nuclear power plant and an "ATWS Mitigating Actuation Systems" panel 36
ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION N0.: 99900225/89-01 RESULTS:
PAGE 9 of 13 for the R. A. Ginna nuclear power plant were in various stages of completion.
5.
Observation of Final Inspections The inspectors visited the clean room where instruments intended for nuclear power plants are assembled and tested.
Instruments requiring repair are also disassembled in the clean room.
Persons entering the clean room are required to wear clean coveralls including caps.
The inspectors witnessed the calibration of a N-E11 DMIIB2-BFL type differential pressure transmitter, serial number 5391270, ordered by the Connecticut Yankee nuclear power plant. The instrument was being calibrated to respond to -5 to 30 psi input pressure and produce a corresponding output signal of 4 to 20 milliamperes (mA).
The purchase order documents were in a file identified " Nuclear Safety-Related." Other documents in the file for this instrument included the following:
a.
A " Nuclear Cleaning Certificate" stating that all process wetted parts were cleaned to Procedure CESA 264, dated February 1,1972.
The procedure requires wetted parts to be cleaned with Acetone, rinsed with distilled water, blown dry with pre-purified nitrogen, and dried in an oven.
b.-
A hydrostatic test report certifying that the enclosure housing the wetted parts withstood 4500 psi for 10 minutes without leaks on January 13, 1989.
c.
A calibration data sheet, dated January 19, 1989, indicating that the instrument was calibrated to produce a 4-20 mA output signal in response to -5 to 30 psi input pressure.
d.
A Certificate of Conformance stating that the above instru-ment met the guidelines for IEEE 344-1975 for seismic qualification.
TFC stated that typically all the parts required to assemble a transmitter are sent to the clean room. After the assembly is completed, the transmitter, without the electronics, is soaked at 300 F for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to relieve stresses. A cover leak test is performed on the transmitter for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 90 psi. The 1
1 37
ORGANIZATION: THE FOXBORO COMPANY FOXBORD, MASSACHUSETTS REPORT INSPECTION N0.: 99900225/89-01 RESULTS:
PAGE 10 of 13 transmitter assembly is then heated to 250*F and maintained at that temperature for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during which the 4 mA output signal at that ambient temperature is verifled. The transmitter is expected to maintain the 4 mA signal during the subsequent cooling to ambient temperature.
Final Acceptance Quality Program Checklist 10115PG is used to inspect the transmitter. All the applicable requirements f or the specific transu.itter are yellow lined to highlight the attributes to be verified.
6.
Review of Control of Purchased Material a.
Control of Material Traceability The inspectors selected the wetted cover for the E-13 series transmitter to review the traceability of purchased material.
This part is identified as Part No.141KB on Parts List 008-567.
The corresponding forging nuniber is No. 141KA, made of 316 type stainless steel material, ASTM-A-182 F316, with a maximum Rockwell Hardness of Rc 22.
Ideal Forging, Southington, Connecticut, supplied 225 pieces to TFC to fill PO 506432, dated October 20, 1988. The receipt inspection checklist indicates that the receipt inspector (identified as OA ctamp 042) inspected 225 pieces to drawing No. 141XC, Revision 2 and rejected none.
The certified iraterial test report (CMTR) identifed heat number 57 42 071, heat code NN, and listeo the tensile strength as 85,000 psi, the yield strength as 41,300 psi, elongation as 48 percent, and reductior, in cross-sectional area as 69 percent. The CMTR provided the ladle analysis for the heat and certified that the material was solution annealed at 7900*F (minimum) and was water quenched to below 800 F in less than 3 niioutes.
This r;aterial was also certifiec tc be free from mercury.
The inspection checklist attributes are:
drawing revision symbol, visual configuration, workmanship (visual), wall thick-ness of 0.25 inches (measurement), heat number and material type clearly stamped on each piece at locations identified on the drawing, CMTR, and other dimensions.
TFC performs a 2-hour salt spray test and inspects the surf ace condition to see if it is free from iron or visible contamination.
The inspectors accompanied by TFC OC personnel went to the storage area, located the area where these covers were 38
[
ORGANIZATION: THE FOXBOR0 COMPANY FOXB0RO, MASSACHUSETTS REPORT lt;SPECTI0tl
'NO.:
99900225/89-01 RESULTS:
FAGE 11 of 13 stored and examined them. The inspectors observed no adverse findings.
b.
Control of Qualified Components TFC initially qualified components manufactured by accept-able vendors, such as resistors and oiodes, used in the manufacture of their electronic assemblies. These compo-nents were invariably used in the assembly which was sub-jected to eouipment qualification tests. After the com-ponent is qualified by type numbers, TFC purchases these components from distributors. All components are inspected after receipt and a failure history is maintained. The inspectors randomly selected six compcnents from the N-2AX+SLM drawing and established that these components were on the " qualified components list. The integrity of the individual componets are confirmed during the final tests.
c.
Control of Nonqualified Components TFC stated that there have been instances where they had to purchase r. unqualified components to replace qualified components which have been rendered obsolete. A noncon-formance report (NCR) is issued in such cases when the components are receiveo. These components are stored in a segregated and controlled area. The performance of the components issued from this lot is continuously monitored and the failure rate is recorded. Components, with unsatisfactory performance, are returned to the vendor.
The inspectors reviewed the following NCR's generated by receipt inspection for such purchases:
(1) NCR l'/, 3, dated December 7, 1986, identified that all of the 117 potentiometers (Part flo. 197MB) received from Greenshaw, Incorporated per P0 931480H45A, were reported defective during receipt inspection.
It was subsequently determined that the venoor had shipped the wrong potentiometers.
Corrective action was to return them to the vendor.
(2) NCR 17695, dated November 11, 1968, identifico that 6500 pieces of part no. 282FJ (diodes originally 39
ORGANIZATION: THE FOXBOR0 COMPANY FOXBOR0, MASSACHUSETTS n
REPORT INSPECTION-
.NO.:
99900225/89-01 RESULTS:
PAGE 12 of 13 manufactured by Fairchild) were purchased through a distributor, per P0 34102H46. The diodes were manu-factured 14 years ago. Three diodes failed electical tests at receipt inspection. Disposition of the NCR recommended the return of the diodes'to the vendor.
(3) NCR 15290, dated March 10, 1987, identified that 14 of the 146 integrated circuit boards, Part No. 4015, i
purchased from Harris Company per P0 926929107A, were 1
defective. Disposition of the NCR required the return of the 14 defective items and reevaluation of the vendor.
(4) NCR 18032, dated January 26, 1989, identified that 1 of 10 triplett indicating meters purchased to P0 1
931163H52B, did not meet the accuracy requirements.
l Furthermore, receipt inspection observed that the pivot jewel movement was sticky and the pointer did not move freely.
Corrective action taken was to return the instrument to the vendor for replacement.
The inspectors consider the dispositions of the NCRs reviewed acceptable.
F.
EXIT INTERVIEW:
The inspectors met with persons identified in Section F and discussed the scope and findings of the inspection.
Persons Contacted Neponset Plant
- Dr. P. F. McCrea Vice President, Research, Design, and Quality Assurance
- S. H. Fazvi Manager, Outlity Assurance
- R. A. Anderson Senior Quality Assurance Engincer
- R. V. Porter Senior Quality Control Engineer J. Rinaldi Product Engineer D. Dicesarc Quality Centrol inspector W. Simpson Instrument Test Technician R. Rodier Supervisor, Molding M. Patel Molding Engineer 40
I ORGANIZATION: THE FOXBOR0 COMPANY FOXBOR0, MASSACHUSETTS
)
. REPORT INSPECTION H0 :
99900225/89-01 RESULTS:
PAGE 13 of 13 i
Highland Plant
- D. Golden Manager, Technical Services
- W.
F. Griffin Supervisor, Quality Control M. Webb Quality Control Inspector G. Gaziano Quality Control Inspector, Procurement R. Bates Quality Control Supervisor, Procurement Cocassett Plant
- E. Morris Engineer, Nuclcar Engineering
- J. R. Brikert Manager, Nuclear Engineering
- M.
Van Dyne Supervisor, Repair Services
- Denotes those individuals who attended the exit interview on February 10, 1989.
41
f Selected Bulletins and'Information Notices Concerning Adequacy of Vendor Audits and Quality of Vendor Products Issued October-December 1988 1.
Information Notice No. 88-046:
Licensee Report of Defective Refurbished Circuit Breakers 2.
Information Notice No. 88-097:
Potential Substandard Valve i
Replacement Parts 3.
List of Parties Excluded From
. Federal Procurement or Non Procurement Programs
'l 4
Failure of Rosemount Models 1153 and 1154 Transmitters 5.
Permanent Defornetion of Torque Switch Halical Springs in Limitorque
.SMA-Type Motor Operators 6.
Metalclad, Low-Voltage Power Circuit i
Breakers Refurbished With Standard Parts 7.
Inf ormation Notice No. 89-52:
Potential Fire Dar.iper Operational Problem I
42
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