ML20141E404

Insp Rept 99901305/97-01 on 970106-09.Major Areas Inspected: Implementation & Control of Quality Assurance Program

ML20141E404
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Issue date:	05/16/1997
From:	Petrosino J NRC (Affiliation Not Assigned)
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ML20141E325	List: ML20141E317 ML20141E404
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REF-QA-99901305 99901305-97-01, 99901305-97-1, NUDOCS 9705200432
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Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE 6F NUCLEAR REACTOR REGULATION Report No.: 99901305/97-01 Organization: C&D*' Charter Power Systems, Incorporated 1400 Union Meeting Road Blue Bell, Pennsylvania 19422-0858 Contact Address: Terry J. Kinden, Director of Quality Assurance Washington & Cherry Streets Conshohocken, PA 19428 (610) 825-2150 ext. 245 2

Facility r&D Powercom Inspected: 82 East Main Street Leola, Pennsylvania Nuclear Industry Manufacturers of Lucent Technologies cylindrical Activity at lead-acid battery cells, Lineaged 2000 Round Cell Facility: batteries (round cells), that are supplied to nuclear pcwer plant facilities for Class IE electrical safety-related applications.

Inspection Date: January 6-9, 1997 Inspectors: Joseph J. Petrosino, Team Leader l

Saba N. Saba, EELB:DE:NRR Stephen D. Alexander, VIS:PSIB: DISP Approved by: Gregory C. Cwalina, Chief Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation 1

C&D is a registered trademark of C&D Charter Power Systems, Inc.

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A division of C&D Charter Power Systems, Inc.

3 Registered trademark of Lucent technologies, Incorporated (formerly known as American Telephone and Telegraph Company [AT&T]).

9705200432 970516 PDR GA999 EMV*****

99901305 PDR ,

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1 INSPECTION SUNNARY '

During this inspection, the NRC inspectors reviewed the implementation of selected portions of C&D Charter Power Systems, Incorporated (C&D) quality 1 assurance (QA) program, reviewed activities associated with the manufacture of 1 round cells, reviewed pertinent design, engineering and manufacturing documents, reviewed the Lucent Technologies, Incorporated (Lucent) manufacturer requirements regarding Lucent's control of C&D's Leola l manufacturing activities, and compared the Lucent requirements-with actual manufacturing procedures and practices. The team was aware that several nuclear plant round cell batteries experienced premature loss of capacity.

l The inspection bases were:

• Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reaulations (10 CFR Part 50) 10 CFR Part 21, " Reporting of Defects and Noncompliance" The American National Standard Institute /The American Society of Mechanical Engineers (ANSI /ASME) Standard N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities" (ANSI N45.2-1977), as '

endorsed by V. S. Nuclear Regulatory Commission Regulatory Guide (RegGuide) 1.28, " Quality Assurance Program Requirements (Design and Construction)," Revision 2, February 1979 (RegGuide 1.28)

Although C&D's quality program for its manufacture of round cells was found to be generally well established and implemented, the team found some weaknesses that are discussed in this report. Those weaknesses are also discussed in NRC Inspection Report 99901309/96-01, Lucent Technologies-Dallas, Texas.

2 STATUS OF PREVIOUS INSPECTION FINDINGS This was the first NRC inspection of C&D's facilities at Leola, Pennsylvania.

3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Ouality Assurance Proaram and Reauirements

a. Scope The inspection team (team) reviewed the establishment and implementation of selected portions of the C&D quality program, which was documented in l the C&D Quality System Program Manual (QSPM), Issue P, dated June 1995.

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! b. Observations and findinas l

The QSPM stated that its purpose was to establish the basic operating policies and procedures to be employed by C&D, and to meet applicable requirements of International Organization for Standardization (IS0)-9001, " Quality Systems-Model for Quality Assurance in 2

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1 Design / Development, Production, Installatior, and Servicing,"

ANSI [N]45.2-1977 and other imposed specifications. The team noted that C&D's Leola facility had been certified to 150-9001.

The team was apprised by C&D that it assures that its components conform to the specified requirements through implementation of C&D's quality system program that is delineated in the QSPM. The QSPM's foreworo explains that C&D's quality system program is implemented through the QSPM, departme 1 standard operating procedures, work instructions, ,

drawings, bills of materials, material specifications, process l specifications, and quality and test procedures. The team reviewed applicable licensee and Lucent procurement documents and did not find any instances where AT&T/ Lucent had imposed any uniqua nuclear quality i assurance requirements upon C&D.

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1 The team noted that the C&D facilities that are under C&D's quality system program are specified in the QSPM, specifically: (1) Corporate Headquarters-Blue Bell, PA-Control and maintenance of design and qualification aspects of all C&D safety-related components; (2) Attica, IN-Class IE station batteries; (3) Dunlap, TN-Class lE station battery i chargers; (4) Conshohocken, PA-seismically qualified, Class lE station I battery racks; (5) Leola, PA-Class lE station batteries, round cell; (6) Conyers, GA-commercial products; (7) Huguenot, NY-commercial products; and (8) Ratelco, Incorporated, Seattle, WA- Jectronics, l including battery charger assemblies used in safety-related applications I of C&D battery chargers.

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c. Conclusions l

The team determined that C&D-Leola manufactured the round cells  !

according to its commercial QA program. No nuclear qualification,  !

manufacturing or testing requirements were imposed onto C&D by Lucent for the manufacture of the round cells.

I 3.2 10 CFR Part 21 Proaram

a. Scope The inspectors evaluated the procedure adopted by C&D to implement the requirements of 10 CFR Part 21 by reviewing Standard Policy and Procedure Number A-14-4, " Reporting of Defects and Nonconformances in accordance with Federal Regulation 10 CFR 21 (US Nuclear Regulatory Commission)," dated March 18, 1997.

b. Observations and findinas Although C&D is not responsible for the requirements of 10 CFR Part 21 at its Leola facility, the team determined that C&D had implemented the provisions of Procedure A-14-4 into its Leola facility round cell i 3

operation for nuclear power plant orders. Additionally, the team noted that documents required by Part 21 had been posted at various locations at the Leola facility.

During a previous inspection, in September 1996, at C&D's Attica, Indiana, facility, the team performed a review of Procedure A-14-4. The review determined that some weaknesses existed in the procedure and C&D committed to modify the procedure to address the NRC concerns within 90 days of the date of Inspection Report 99901304/96-01, (March 17, 1997).

Procedure A-14-4 had not yet been revised and provided to the C&D-Leola facility,

c. Conclusions The team did not identify any concerns in this area.

3.3 Imolementation and Control Of Ouality Proaram

a. Scope During the inspection at the C&D-Leola facility, the team observed manufacturing activities and reviewed associated documents to assess the adequacy of the manufacture of the rouna cells.

b. Observations and Findinas Process Controls The team observed numerous manufacturing process control activities at C&D's facility and reviewed associated documents.

The team noted that many of the C&D manufacturing work stations had key sections of the applicable process control work instructions posted for use of the area personnel. The team also noted that a Lucent required resident inspectcr is stationed at the C&D facility. The resident inspector is typically on the premises several days a week. The resident inspector witnesses testing activities of round cell battery strings, and performs in-process manufacturing verifications and random inspection of incoming material. No anomalies were noted by the team in the manufacturing process control activities that were observed.

Charaina & Conditionina The team performed a comparison of the C&D procedures, practices and documentation used during the process of initial charging and conditioning of round cell strings with the charging and conditioning requirements (design bases) of Lucent's design and manufacturing specification KS-20472 and associated documents. The team reviewed the charging records for string 345-96 for McGuire Station and strings 223-92 and 224-92 for Oyster Creek.

C&D conducts all of its manufacturing activities (including charging and conditioning) in the same manner, in accordance with its documented ISO-9001 quality system in conjunction with Lucent's design and specification documents. However, the team identified several instances 4

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l in which C&D's procedures, practices and documentation for the charging and conditioning process departed from the requirements of the Lucent design specification. The following are examples of these departures:

KS-20472, Section 5.25, Step (c), prescribed the initial formation charge for the string. The step included a cautionary note that stated that the cell temperature should not be allowed to exceed a certain value. Although C&D stated that the temperatures are monitored, they were not recorded, nor was there a provision in the  ;

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C&D record forms to do so. )

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• KS-20472, Section 5.25, Step (d), prescribed the first conditioning l discharge following the initial formation charge, per Table II for i List IS round cells, to be a certain amperage for a certain i f duration. This discharge removed a specific amount of ampere (ah) from each cell of the string. The step included the warning-"No individual cell should be allowed to go below [specified] volts."

KS-20472, Section 5.25, Step (e) required that, following the Discharge, the string be recharged to a specific percentage of the ampere-hours removed during the discharge for a minimum time duration. This charge then should have restored a minimum and a maximum value.

However, the overall charging record sheet, called " Procedure Sheet 1," was pre-printed with the annotation, "[specified number) amps for [certain number of] hours" for this charge. This charge would put in more ampere-hours than allowed by the specification.

Although C&D produced a 1986 memorandum from Lucent (then AT&T/ Bell Laboratory) authorizing this departure from KS-20472, the specification had not been updated, in over four years, to reflect this modification to the prescribed charging and conditioning (C&C) process. The charge records reflected that the string was, in fact, recharged per Procedure Sheet 1 instead of KS-20472.

KS-20472, Section 5.25, Step (f), prescribed a "First Taper Discharge," per Table III for List IS round cells, to be for a specific periods at certain current values to remove a specific number of ampere-hours. The first post-taper recharge per Step (g) was supposed to ensure that a certain percentage of the ampere-hours were removed in the previous discharge. However, Procedure Sheet I was pre-printed with the annotation, "[specified value] amps for

[certain number of] hours" followed by "[specified value of] amps for [certain number of] hours," more than allowed by the specification. Although C&D produced another 1986 memorandum from Lucent (then AT&T/ Bell Laboratory) authorizing this departure from KS-20472, the specification did not reflect this four-year old

design basis change to the prescribed charging and conditioning

(C&C) process. The charge records reflected that the string was recharged per Procedure Sheet 1 instead of KS-20472.

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I KS-20472, Section 5.25, Steps (h) and (j), prescribed the required sequential "[specified value]-Amp Discharges." The steps stated

" Discharge at the Table IV rate until the first cell reaches

[specified value] volts." Howeve',, C&D 01-20-0900.2, " Charging" i (Section 6.3.16, " Water Discharges"), did not provide for normal '

discharge termination upon reaching a prescribed voltage (on the first cell to reach it). Instead, Step 6.3.16.3 called for termination "at the normal discharge end time." The note above step ;

6.3.16.3 stated: "If any cell has a voltage of [certain number of]  ;

volts or less, terminate the discharge and notify your supervisor." l Therefore, the C&D procedure called for discharging until an end time that is not defined as the termination point for this particular discharge in KS-20472. Also, the C&D procedure prohibited allowing any cell to go below a certain voltage, but did not require discharging until reaching a specified voltage on the

1. irst cell that reaches this voltage as the language of the Lucent specification states.

In view of the explicit language in Step (h) of the specification (as distinguished from language explicitly prohibiting discharging below a specified voltage elsew'1ere in the specification), the language in the C&D OI was contrary to the requirements of specification KS-20472. As a result, the charge records showed that both specified discharges went only to a certain voltage on the lowest cells. Although the practice of discharging until the first cell reached the specified voltage (instead of the prescribed voltage) had been authorized in 1986 on a limited, experimental basis, C&D could not provide documentation authorizing this departure from KS-20472 for general production use. This resulted in the string not being discharged in this step to the extent required by KS-20472.

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KS-20472, Section 5.25, Step (i), prescribed the recharges for the two sequential "[specified value]-Amp Discharges" of Steps (h) and (j) respectively. The recharges were supposed to be a specified percentage of the ampere-hours removed in the previous discharge.

Since both discharges continued for several hours, they were discharged tu a certain value. Therefore, according to the MS-20472 formula, a specified minimum of the ampere-hours should have been recharged. However, Procedure Sheet I was pre-printed with the annotation, "[specified value of] amps for [certain number of]

hours," less than required by the KS-20472 formula using the abbreviated discharges. This was also much less than intended by KS-20472 because the recharge amount, even if calculated and performed in accordance with the KS-20472 formula, would have been based on a discharge to a non.inal voltage, less than the amount of discharge specified by KS-20472 in Steps (h) and (j).

KS-20472, Section 5.25, Step (k), prescribed a "Second Taper," or

"[specified value]-amp Taper" discharge per Table V for List IS round cells, to be conducted in several steps at specific values.

Step (1) required discharge to "[a specified value of] volts per 6

i cell average," or for a specified ampere-hour value with the caution that no cell should be allowed to go below a certain voltage.

However the discharge record (Form RS533) showed that no cell went below the minimum allowed voltage during the phase and none reached  !

the specified voltage during any part of the second taper discharge.

Although the minimum total ampere-hours were discharged, no cell "

achieved the lowest voltage specified by KS-20472.

The final 7 acity testing specified by KS-20472 following charging j and conditioning was modified for Strings 223-92 and 224-92 by a j procedure required by Lucent's customer, GPU Nuclear, licensee for Oyster Creek. GPU Nuclear had contracted National Technical Systems (NTS), Inc., of Acton, Massachusetts, to perform the dedication of l the round cell strings for Oyster Creek purchased from Lucent as '

commercial grade items. NTS Procedure 60145-93N, Revision 2, was used as the basis for dedication of the strings. The NTS dedication procedure modified the standard capacity test discharge rate following the specified float period prescribed in KS-20472. ,

Instead, the NT! procedure called for a high-current discharge,  !

recharge, and a several hour discharge, intended to better simulate design basis service conditions at Oyster Creek. The test record contained a notice of anomaly indicating that only 95-percent capacity had been demonstrated by the discharge tests, but that this was acceptable. The explanation of the reduced capacity was the 3 interruption of the standard " conditioning" sequence to perform the i NTS dedication tests. However, this language did not accurately l characterize the circumstances in that the conditioning phase of the KS-20472 process, including the final several-day float charge, was, in fact, completed. Only the final capacity test discharge, not h considered part of conditioning, was omitted in favor of the NTS multiple hour discharges. ,

a In reviewing the test and cell selection records for strings 223-92 l and 224-92, the inspector noted that one test for 223-92 was  !

terminated several minutes early. A notice of anomaly (NOA) also 1 noted the early stop, but had the wrong time. In addition to the i records having a number of other anomalies, such as not all forms  !

being fully or correctly filled out and some erroneous operation l ending times recorded. For example, one recharge for a specific I discharge was listed as staring at a certain value on 11/21/92, but ending at the same value on 11/22/92, a longer period than specified on Procedure Sheet 1; yet, the second discharge was recorded as starting earlier on 11/22, and the inspector believed this entry to i likely be the correct one. The charge end time entry of the first  !

entry on 11/22 was apparently in error, but there was no indication  !

that the record had been reviewed and the error identified by C&D l QA, engineering or management or representatives of Lucent or GPU '

Nuclear.

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. The inspector also noted that the cell in position 43 in string 223-92 (cell serial no. 78471) finished the test with a low-out-of- t specification' voltage, yet this cell was selected for shipment by GPU Nuclear according to the selection record. Conversely, although j the cell in position 64 had a low voltage, but met the acceptance i criterion, it was rejected. The record indicated no rationale for '

the apparently inappropriate cell selection, nor could C&D offer any_

explanation.:

The inspector also reviewed the charging and conditioning records-for round cell string 345-96, produced for Lucent's customer, Duke '!

Power for_ Class IE service at McGuire Station. The same process was '

used for.this string as for the Oyster Creek strings discussed above -)

except that the standard final capacity test discharge was 3 conducted.- Therefore, _ this string underwent charging and J conditioning with the same deviations from KS-20472 as occurred with )

the-0yster Creek strings, only some of which, as above, had.ever I been authorized by Lucent memorandum, and still without formal revision to KS-20472 (Issue 8 still in effect).

Chemical Analysis of Epoxy Mixture The team reviewed the applicable section of KS-20472 regarding preparation and mixture verification of epoxy used to. seal the round cell jars around the terminal posts. Also reviewed were the Lucent epoxy titration procedure referenced by ,

KS-20472 that was prescribed on AT&T Drawing L193472,-Issue 5, and the j C&D epoxy titration procedure, BT-4, Revision 0, dated March 7, 1995.

The procedures specify'the quantitative analysis by titration of percent

, resin in hardener (done on each new mixed batch) and of the equivalent weight of hardener (done on each lot of hardener and each shift), the -

results of which are used in the percent-resin-in-hardener analysis calculation.

Following this review, the team observed a routine set of epoxy titration analyses, performed by C&D's usual analyst'in the C&D laboratory. The analyses observed were the determination of percent hardener in resin, and the determination of the equivalent weight of hardener. The team identified two instances in which C&D epoxy titration procedure BT-4 deviated from AT&T Drawing L193472, i specifically:  !

q L193472 called for titrating into the sample in a 125-m1 Erlenmeyer flask; whereas BT-4 prescribed a 250-m1 flask, and r L193472 required adding a specific number of drops of Brom Creosol green indicator; whereas, BT-4.specified a range of drops that.could be.added.

The team also determined that the size of the flask can affect the efficiency of mixing of the sample (by means of a magnetic stirrer) with )

the indicator, and more importantly, with the drops of titrant (sulfuric  ;

acid). The amount of indicator added can affect the visibility of the  !

endpoint. Other deficiencies in C&D procedure BT-4 noted were. ,

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The C&D procedure inappropriately defined the titration endpoint as I a color change from blue to vellow; however, the analyst correctly l described the color change as being from blue to areen.

• The acceptance criteria for percent-hardener-in-resin and for hardener equivalent weight given on L193472 were not in the C&D procedure for use by the analyst, although the analyst was familiar 1 with them. '

l No sample vortex characteristics were specified to ensure uniform mixing in the flask.

The team observed two instances in which the analyst deviated from C&D procedure BT-4: j

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Instead of the 250-ml Erlenmeyer sample flask specified by BT-4, the i analyst used a 125-m1 flask as specified by the Lucent drawing; I although the analyst was unaware of the drawing requirement. He l explained, correctly, that for the specified 50-ml sample size, the  !

smaller flask provided the depth of liquid necessary to achieve an '

adequate vortex (using the specified magnetic stirrer) for proper  ;

r:ixing of the indicator and the titrant in the sample. l The C&D analyst stated that he typically adds more drops of i indicator than that specified in BT-4, nearly twice as much {

indicator as specified in drawing L193472. 1 In addition, the analyst did not employ the standard titration technique when near the expected endpoint of so-called " drop splitting" or " drop transfer" using a glass rod to take each drop allowed to form at the burette nozzle as the titrant level is lowered by the smallest burette graduation and placing the drop in the sample. Instead, the analyst simply slowed the expected near-endpoint rate of titration to about I drop per second, which may not allow for complete mixing and reaction of the titrant with the sample and indicator so as to show the endpoint when it first occurs before the next drop falls into the sample. This practice, with a less experienced analyst, and also using the 250-m1 flask if BT-4 were followed, could cause the actual endpoint to be missed, thus degrading the sensitivity of the analysis or the accuracy of the results.

Audits and Surveillance of C&D-Leola by AT&T/ Lucent A review of the AT&T Quality Management & Engineering Department (QM&E) audits and surveys indicated that AT&T/ Lucent performed on-site audits of C&D to observe their capabilities and performance as required by Lucent's quality par ual and technical specifications and drawings. The team noted that the QM&E personnel identified numerous quality problems over a several year period. However, contrary to the 10 CFR Part 50, Appendix B, quality assurance requirements which were imposed upon AT&T/ Lucent, the team determined that Lucent did not take prompt action to address the effectiveness of C&D's control of product quality. That l is, although Lucent identified numerous examples of conditions adverse 9

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l to quality over a three year period at the C&D-Leola facility, Lucent did not promptly correct those conditions adverse to quality identified or assure that C&D addressed the ineffectiveness of its program implementation consistent with the importance and complexity of the round cell product. It was also noted that the quality and reliability of the product that was shipped to nuclear power plants did not appear to be cddressed in the documents reviewed by the team.

Consequently, the team determined that Lucent did not assure that the manufacturing services that it contracted from C&D, for fabricating its round cells for at least the McGuire station, consistently conformed to the procurement document specifications and requirements during the charging and conditioning manufacturing activities.

2 For example, a November 2,1994, AT&T Bell Laboratories letter to the C&D Leola facility quality control (QC) Manager and associated documents discussed the findings of a September 21, 1994, mini quality audit of the round cell manufacturing and quality systems. AT&T's correspondence l indicated that 15 separate areas were investigated during a period when C&D was in the process of increasir,g production rates of its round cells. The correspondence indicated that 11 of the 15 areas audited did not conform to AT&T's specification requirements. The correspondence also indicated that in light of a recent problem encountered with 1992 series ISH cells sold to Arizona Public Service (Palo Verde), "it would behoove C&D to spend additional time and effort on training new .

employees and increasing inspection" at those operations where these new I employees are located. The conclusion reached by the AT&T auditors was that the overall round cell quality was not up to usual standards. The letter to C&D itemized specific areas of concern and requested C&D's '

corrective action plan.

A December 19, 1994, AT&T Bell Laboratories Trip report documenting a December 14, 1994, follow-up mini quality audit stated that C&D had not compiled or composed the required corrective action plan, and the overall manufacturing process quality was found to be lower than C&D's  ;

usual standards. The trip report stated that although the observed '

deficiencies were not critical, they indicated "a general relaxation in standards."

The December 1994 report stated that on December 14, the inspection of round cell manufacturing process quality indicated that the manufacturing quality standards were continuing to trend downward. The letter indicated that the observation had been made over a period of time, was not specific to any one area, and that C&D's emphasis on quality and the commitment to quality have diminished over the last six months. The staff engineer recommended that AT&T and C&D meet to address both Companies' concerns and to " refocus on the critical j importance of quality to this product's continued success."

Three months later on March 15, 1995, another mini quality audit was conducted and identified findings in 18 areas at the C&D-Leola facility.

The overall conclusion reached was that " quality is poor." The AT&T 10

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I staff performing the audit stated that work instructions need to be l reviewed with both the operators and C&D quality control inspectors and

! the importance of producing good quality parts needs to be reinforced, j

! c. Conclusions No anomalies were noted by the team in the manufacturing process control activities that were observed during the performance of this inspection.

However, in ti.. .harging and conditioning process area, the team l

1 concluded that:

= C&D charging and conditioning procedures and practices deviated from KS-20472 and only some of the departures were authorized by Lucent i which had not updated its coecification in several years to reflect the different practices C&D procedures were not always followed and records were not always fully accurate, nor apparently carefully scrutinized by Lucent, the ultimate user or its representatives, and

= the 64 cells selected by GPU Nuclear from each of the 72-cell l

strings produced and tested, did not all meet the acceptance I criteria following the final test discharge. '

In the chemical analysis of epoxy mixture area, the team concluded that the anomalies from the AT&T/ Lucent drawing as well as the quantitative analysis practices employed could affect the accuracy and repeatability of the epoxy titration analyses for percent-resin-in-hardener and equivalent weight of hardener.

Additionally, although there is a wide range in the acceptance criteria j for the epoxy titration analyses, the team was given the understanding -

that neither Lucent nor its customers had identified any of the anomalies observed by the team in the titration process. Therefore, the effects of these anomalies had not been evaluated by Lucent or their customers to determine their significance.

The team concluded that the AT&T/ Lucent auditors identified negative quality aspects that would be indicative of an ineffectively established or implemented quality program. However, the team noted that neither Lucent nor C&D took appropriate measures to determine the cause of the problem and implernent corrective action.

Additionally, neither the product or process appeared to be appropriately questioned regarding quality and reliability of the product. These issues are also discussed in NRC's inspection results of Lucent's Dallas, Texas facility, Inspection Report 99901309/96-01-02.

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3.4 Entrance & Exit Meetina In the entrance meeting on January 6, 1997, the NRC Team Leader discussed the scope of.the inspection, outlined the areas to be inspected, and established interfaces with C&D management. In the exit meeting on January 9, 1997, the inspectors discussed their findings and Concerns.

3.5 PERSONS CONTACTED C&D Charter Power Systems. Inc.

G. Stoermer, Plant Manager-Leola T. Kinden, Director, Quality Assurance

.D. Johnson, Q.C. Manager Lucent Technoloaies-Bell Laboratories. Murray Hill. New Jersey Staff M.C. Weeks, Technical Staff J.B. Baldasty, Technical Staff i

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