ML090350217
| ML090350217 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Oconee, Mcguire, Indian Point, Catawba, Seabrook, North Anna, Cook, McGuire  |
| Issue date: | 01/27/2009 |
| From: | Farrell M Fisher Controls International |
| To: | Office of New Reactors, Office of Nuclear Reactor Regulation, NRC Region 1, NRC/RGN-II, NRC/RGN-III, NRC Region 4 |
| References | |
| 44808 | |
| Download: ML090350217 (7) | |
Text
J 0 1/2 712009 U.S. Nuclear Regulatory Commission Operations Center Event Report PokeeI General Information or Other (PAR) Event# 44808 Rep Org: FISHER CONTROLS INTERNATIONAL Notification Date / Time: 01/27/2009 17:11 (EST)
Supplier: FISHER CONTROLS INTERNATIONAL Event Date / Time: 01/27/2009 (CST)
Last Modification: 01/27/2009 Region: 3 Docket #:
City: MARSHALLTOWN Agreement State: Yes County: License #:
State: IA NRC Notified by: MATTHEW FARRELL Notifications: WAYNE SCHMIDT R1 HQ Ops Officer: HOWIE CROUCH GERALD MCCOY R2 Emergency Class: NON EMERGENCY PATTY PELKE R3 10 CFR Section: CHUCK CAIN R4 21.21 UNSPECIFIED PARAGRAPH TOM HERRITY NRR OMID TABATABAI NRO PART 21 REPORT - WATER QUALITY DEFICIENCY The following information was obtained from Fisher Controls International via facsimile:
Fisher Controls International issued a Fisher Information Notice: FIN 2009-02, that notified customers of an issue discovered during an internal audit of manufacturing procedures followed by Fisher Controls International LLC.
Specifically, on orders processed by Fisher Controls that invoked demineralized water cleaning requirements, Fisher Controls erroneously certified that all orders met demineralized water requirements when all requirements could not be proven to be met.
To meet the certification requirements, demineralized water must meet the quality requirements of NQA-1. Fisher Controls uses FMP [Fisher Manufacturing Procedure] 12B3 to verify that demineralized water used to clean parts meets NQA-1. Fisher determined that water quality testing using FMP 12B3 performed from January 1, 2001 to May 1, 2008 did not meet the test protocols.
"Twenty two orders have been identified, from 500+ orders reviewed, which require either the use of demineralized water and/or NQA-1 high quality water for which Fisher cannot prove full compliance. It is important to note that this review was limited to nuclear assembly orders only. Safety-related parts orders were not included because final cleaning was done either with alcohol or acetone."
The affected plants are:
Indian Point 2 Seabrook Millstone (two valves)
It..
01/27/2009 U.S. Nuclear Regulatory Commission Operations Center Event Report Pag'e 2 General Information or Other (PAR) Event# 44808 D.C. Cook North Anna (two valves)
Catawba (seven valves)
-Oconee (five valves)
McGuire (three valves)
Jan. 27. 2009 4 :08PM No. 0213 P. 1 EMERSON [FISHER]
Facsimile 301 South First Avet Marshalltown, IA50158 T 641-754-2688 F 641-754-2645 To: NRC Operations Center Fax: 301-816-5151 Dave A. Suk From: Director, Quality Valves Worldwide Date: January 27, 2009 Pages: 7 (inc cover)
Attached Is a copy of the Nuclear FIN Notice - FIN 2009-02 issued January 22 and FIN 2009-03 issued January 23 from Emerson Process Management - Fisher Controls International LLC.
For questions please contact- Matthew Farrell QA Manager Codes & Standards 641-754-2381
Jan. 27, 2009 4:08PM No. 02 13 P. 2 EMERSON,. Fisher Controls International LLC Pi r:wrlss IfI/lanagq en-it 205 Soulh Canter Street P.O. Box 190 Marshalltown, Iowa 50158-0190 USA T (641) 754-3011 F (641) 754-2830 Fisher Information Notice: FIN 2009-02 22 January 2009
Subject:
Water Quality Deficiency - Fisher Orders Invoking Demineralized Water Cleaning Requirements or NQA-1 High Quality Water Requirements From:
Bill Fitzgerald Nuclear Business Unit Vice President Fisher Controls International LLC 205 South Center Street Marshalltown, IA 50158 Fax: (641) 754-2854 Equipment Affected By This Information Notice:
ORDERS PROCESSED BY FISHER CONTROLS THAT INVOKED DEMINERALIZED WATER CLEANING REQUIREMENTS OR NQA-1 HIGH QUALITY WATER REQUIREMENTS.
Purpose:
The purpose of this Fisher Information Notice (FIN) is to notify customers of an issue discovered during an internal audit of manufacturing procedures followed by Fisher Controls International LLC.
We have informed our customers of record of this circumstance in accordance with 21.21 (b) of 10CFR21 because Fisher Controls International LLC, is not aware of each and every application or system design and cannot determine whether an anomaly could cause a defect or "failure to comply," relating to a substantial safety hazard. In particular, this Information Notice deals with customer orders that invoked demineralized water cleaning requirements per NQA-1 or per individualized customer specifications.
Receipt of this notice does not necessarily mean that the recipient has been shipped any of the subject equipment. It is expected that the recipients of this notice will review the information for applicability to their facilities, and if required, take the appropriate action as described in the section at the end of this notice.
Applicability, This notice applies only to customer orders requiring specific cleaning with demineralized water or NQA-1 High Quality water requirements that were supplied by Fisher Controls International LLC. Customer orders affected by this notice are listed in an attachment following this notice.
[FISHER] Page 1 of 4
Jan, 27, 2009 4:09PM No 0213 P. 3 Fisher Information Notice: FIN 2009.02 Although Fisher has identified orders that specifically required cleaning with demineralized water, Fisher's Nuclear Manufacturers Certification form erroneously certified that all orders processed by Fisher Controls met demineralized water requirements.
Description of Possible Concern:
NQA-1 Requirements. Water quality testing performed from January 1, 2001, to May 1, 2008 did not meet the test protocols required by NQA-1-1994 or NQA-1-1997 for high quality water.
For NQA-1, Subpart 2.1, Table 3.4.1 High Quality Water the following requirements apply:
- pH 5.5 to 8.0
" Chloride Less than 1.0 ppm
- Fluoride Less than 1.0 ppm
- Sulfide Less than 1.0 ppm
" Silica Less than 0.05 ppm
- Conductivity at 25 C (77 F) Less than 3 mho/cm
" Total Suspended Solids Less than 3.0 ppm It is not possible with the data available to verify that Fisher was in compliance in this time period because testing was not performed to adequate levels as well as missing test data.
FMP 12B3 Requirements. In addition to the requirements of NQA-1, Fisher Controls determined that additional test protocols were not met as required by Fisher internal manufacturing procedure FMP 12B3, "Demineralized Water- Testing &Control (0.1 PPM Halides)".
- Sodium Less than 1.0 ppm
- Zinc Less than 0.1 ppm Again, it is not possible with the data available to verify that Fisher was in compliance in this time period because testing was not performed to adequate levels as well as missing test data.
Manufacturer's Certification Form for Nuclear Safety-Related Items. The Fisher Manufacturer's Form for Nuclear Safety-Related Items states that all metallic parts were cleaned per N45.2.1 Class C (FMP 7X5). Fisher Manufacturing Procedure FMP 7X5, "Cleaning of Metal Parts for Nuclear Applications per ANSI N45.2.1 - Special Cleaning - Less than 1.0 Halogens", references FMP 12B3 as the requirements for demineralized water. Whether the order specified a demineralized water cleanliness requirement, all orders processed in this time period were incorrectly certified to having met this requirement because of.the problems with FMP 12B3 above.
Discussion:
[FISHER] Page2 of 4
Jan, 27, 2009 4:09PM No. 02 13 F. 4 Fisher Information Notice: FIN 2009-02 It Is also Important to note that the water used in this application was treated through reverse osmosis and subsequent resin beds. This process was designed to accommodate the high water quality requirements mentioned above.
Although objective evidence is not available to determine why this issue occurred, it is believed that the loss of key personnel and realignment of staff created a situation where ownership relating to water quality compliance was lost. Consequently, water quality issues were not reviewed by internal or external auditing activities. Currently, resources have been allocated to remedy this issue and ensure compliance and ownership. Fisher Manufacturing Procedure FMP 122B3 has now been revised to require corrective action per the Fisher Nuclear Quality Assurance Manual.
Twenty two orders have been identified, from 500+ orders reviewed, which require either the use of demineralized water and/or NQA-1 high quality water for which Fisher cannot prove full compliance. It is important to note that this review was limited to nuclear assembly orders only.
Safety-related parts orders were not included because final cleaning was done either with alcohol or acetone.
Action Required:
0 No action is required if you have not ordered items with demineralized water cleaning requirements.
- Fisher has identified customer orders with this processing requirement and is including a list applicable to each site as an attachment to this Information Notice. It is recommended that these customers review these specified orders and determine if on site cleaning was performed prior to installation that would minimize issues raised by this information notice.
IOCFR21 Implications:
Fisher Controls requests that the recipient of this notice review it and take appropriate action in accordance with 1QCFR21.
If there are any technical questions or concerns, please contact:
Michael Wedemeyer Manager, Quality Rsher Controls International LLC 205 South Center Street Marshalltown, IA 50158 Fax: (641) 754-2854 Phone: (641) 745-2066 Michael.WedemeyeraEmerson.com FISHER] Page 3 of 4
Jan. 27. 2009 4:09PM No. 02 13 P. 5 Fisher Information Notice: FIN 2009-02 Orders Requiring High Quality Demineralized Water Fisher Order Customer Order Utility Plant Site 001-AO1268387A 4500530589 Entergy Nuclear Northeast Indian Point 2 002-A009062678 02204897 FPL Energy Seabrook Seabrook 002-A009028488 03000028 Dominion Millstone 002-A009052284 45291649 Dominion Millstone 011-A005121583 190-0000040452 American Electric Power Cook 032-1086203791 45514789 Dominion Virginia Power North Anna 032-1086205366 45529908 Dominion Virginia Power North Anna 033-8800126834 DP12719 Duke Energy Catawba 033-A003072573 ON45757 Duke Energy Oconee 033-A003076619 CN52214 Duke Energy Catawba 033-B800136389 DP15013 Duke Energy McGuire 033-B800137867 DP18148 Duke Energy Catawba 033-B800141716 NM25345 Duke Energy Catawba 033-B8001 41832 NM25344 Duke Energy Catawba 033-B800144580 NM26273 Duke Energy Catawba 033-B800151240 00082526,. Rev. 4 Duke Energy Oconee 033-9800158219 00090265, Rev. 2 Duke Energy McGuire 033-B800163808 DP16169 Duke Energy Oconee 033-B800163809 DP16170 Duke Energy Oconee 033-B800163810 DP16655 Duke Energy Oconee 033-1800115814 DP6565 Duke Energy Catawba 033-B800119093 DP8669 Duke Energy McGuire
[FISHER] Page 4 of 4