ML20207S333
| ML20207S333 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/1987 |
| From: | Baker E, Trottier E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207S267 | List: |
| References | |
| REF-QA-99901079 99901079-87-01, 99901079-87-1, NUDOCS 8703190282 | |
| Download: ML20207S333 (5) | |
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ORGANIZATION: WESTFRN ENGINE COMPANY ITASKA, ILLIN0IS REPORT INSPECTION INSPECTION NO.: 99901079/87-01 DATE: 1/26-30/87 ON-SITE H0llRS: 54 CORRESPONDENCE ADDRESS: Western Engine Corrpany ATTN: Mr. Lawrence J. Smith Vice President and General Manager
) 750 Poute 53 Itaska, Illinois 60143 ORGANIZATIONAL CONTACT: Scott M. Schipitz, Manager, Quality Assurance TELEPHONE NUMBER: (312) 773-5662 NUCLEAR INDUSTRY ACTIVITY: Parts and services for Gereral Motors / Electro-Motive Division (GM/EMD) standy diesal cenerator sets at commercial nuclear power plants.
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ASSIGNED INSPECTOR: " MA N '
E. H. Trottier, Reactive Irspection Section (RIS) Date s
OTHER INSPECTOR: W. P. Haass, Program Coordination Section, VPB l
APPROVED BY: (AAh.44 N UT rd T. Baker, ting Chief, RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 50, Appendix B % i 10 CFR Part 21.
B. SCOPE: This inspection was perfon ed to 'eview the content and imple-mentation of the 'lestern Engine Company,10 CFR Part 50 Appendix B quality assurance progran, measures taken tr comply with 10 CFR Part 21, and the effectiveness of information exchange between GM/EMD, Westerr Engine Compeny, and their curtoners.
f PLANT SITE APPLICABILITY: Dresden 2/3 (50-237/249); Cuad Cities 1/2 (50-254/
265); Vewaunee (50-305); Byron 1/2 (50-454/45M; and LaSalle 1/2 (50-373/374).
8703190282 870317 PDR GA999 ENVWENGE 99901079 pop i
J ORGANIZATION: WESTERN ENGINE COMPANY ITASKA, ILLIN0IS REPORT INSPECTION N0.: 99901079/87-01 RESULTS: PAGE 2 of 5 A. VIOLATIONS:
Contrary to Section 21.6(a) of 10 CFR Part 21, Western Engine Company accepted and fulfilled two purchase orders (P0s) 103394 and 308615 that imposed the requirements of 10 CFR Part 21, yet Western Engine Company did not have a Part 21 progren. (87-01-01)
B. NONCONFORMANCES:
- 1. Contrary to Item 8 of the Procedures for Order Processing of Nuclear Parts Orders, P0 103394 dated June 20, 1986 for parts used in standby diesel generators at a commercial nuclear power station was accepted and fulfilled by Western Engine Corpany, yet require-ments for Part 21 and Part 50 Appendix B programs were not satisfied, and the discrepancies were not identified on a Receiving Inspection Report. (87-01-02)
- 2. Contrary to Section 4.5.3 of the Procedures for Quality Assurance, a "naster" anneter (Model YEW, Type 2013) being used to test an engine's output had no sticker on it to identify its calibration status. (87-01-03)
- 3. Contrary to Section 1.5 of the Procedures for Quality Assurance, evidence of only one audit could be found since the QA Procedures were rewritten and issued as a OA Manual in December, 1983.
(87-01-04)
- 4. Contrary to Section 1.4 of the Procedures for Cuality Assurance, e record is not kept to show distribution of the QA manual. (87-01-05)
C. UNRESOLVED ITEMS:
The inspector spent considerable time discussing the relative merits of having/not having either a 10 CFR Part 50, Appendix B, or 10 CFR Part 21 program. These issues are complicated by the "conmercial grade" umbrella under which GM/EMD sells parts to their distributors (e.g., Western Engine Company). While it is certainly legitimate for GM/EMD to supply commercial grade items (out of their catalcgue and off the shelf) for use in any industrial application, the issue confronting Western Engine Company is what to do when they receive P0s that specify the requirements of 10 CFR Part 21 ard/or 10 CFR Part 50, Appendix B apply.
ORGANIZATION: WESTERN ENGINE COMPANY ITASKA, ILLIN0IS REPORT INSPECTION RESULTS: PAGE 3 cf 5 N0.: 99901079/87-01 In the matter of 10 CFR Part 21, it is clear that suppliers of commercial grade items are not bound by this regulation. However, "nothing in these regulations should be deemed to preclude either an individual or a manufacturer / supplier of a commercial grade item...not subject to the regulations in this part from reporting to the Commission a known or suspected defect or failure to comply and, as authorized by lav, the identity of anyone so reportine vill be withheld from disclosure."
(10CFRPart21,Section21.2.i. Therefore, Western Engine Company may choose to honor the intent of 10 CFR Part 21, but should take exception to P0s that specify their formal participation (posting of 10 CFR Part 21, section 206 of the Enercy Reorganization Act of 1974, and procedures adopted to implement 10 CFR Part 21). It should be made abundantly clear that in the continuing absence of a 10 CFR Part 21 procram, Western Engine Company takes explicit exception to any P0 imposing 10 CFR Part 21, and that dedication (occurs after receipt when part is designated for use in service that is "important to safety") is performed by the customer (i.e., nuclear utility).
The issue of an adopted and implemented 0A proaram that meets the reouire-nents of 10 CFR 50, Appendix B is similar. Although Western Engine Company's Procedures for Quality Assurance approximate those " managerial and administrative controls" found in Appendix B, no statenent or evidence of a conscious decision to address and structure their program to meet Appendix B requirenents was found. Therefore, in the absence of evidence to the contrary, Vestern Engine Company should not accept P0s that impose such requirements, and others that are not met (e.g.,
ANSI N45.2), as though they do meet the stated administrative and procedural requirements.
D. OTHER FINDINGS AND COMMENTS:
- 1. Control of Purchased Material, Eouipment, and Services P0 103394 fron Wisconsin Public Service Corporation (Kewaunee Nuclear Plant) dated June 20, 1986, bears conflicting purchase requirements that could not be satisfied by Western Engine Company.
Page three of P0 10339a requires both a 10 CFR Part 50, Appendix B program ard a 10 CFR Part 21 program be in effect at Vestern Engine Company. However, on page eight of this P0, the recuirement for a 10 CFR Part 21 program is confused by the statement, "WPS [Wiscensin Public Service] considers this part to be commercial grade material used in systems important to safety, and will perform a receiving inspection upon receipt of material, per 00AP [0perations OA Program]
Section 6, paragraph 3.1.4."
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ORGANIZATION: WESTERN ENGINE COMPANY ITASr.A, ILLINOIS REPORT INSPECTION N0.: 99901079/87-01 RESULTS: PAGE 4 of f PO 30815 from Commonwealth Edison Company (Ouad Cities Nuclear Power Station) dated July 10, 1986 explicitly imposes tha require-ments of 10 CFR Part 21 on Western Engine Company in the following statement, "These Items are Safety Related and 10 CFR Part 21 is Applicable." Western Engine Company has no 10 CFR Part 21 program, yet fulfilled this P0. No evidence was found that Western Engire Company identified this discrepancy as inconplete or incorrect documentation. Further, no evidence was found to indicate that Commonwealth Edison was ever questioned regarding the Part 21 requirement it imposed on Western Engine, even though the Commonwealth Edison buyer's name and telephere numbar appear na the front page of the P0. (See Violation 87-01-01 and Nonconferrance 87-01-02)
- 2. Control of Measuring and Test Equipment In reviewing Western Engine Company's calibration proaram the inspector noted that an engine test area ammeter had no celibration sticker. The ammeter, along with an accompanying voltmeter, were, in fact, current in calibration status. These test meters were calibrated by Meter Master, Inc. on April 28, 1986 and are not due for recalibration until April 28, 1987 While this information was available in the OA Department, withcut a calibration sticker on the meter, the test technician has no reliable way to control the potential use of out of calibration test equipment. (See Nonconformance 87-01-03)
- 3. Audits The inspector reviewed the only internal audit checklist presented.
It was dated July 7, 1986. The Procedures for Quality Assurance were issued as a QA Manual on December 1, 1983. Thus, given a six-month internal audit frequency, four mora internal audits should have been performed to date. The inspector noted that an internal audit was scheduled for February, 1987. (See Noncon-formance 87-01-Ca)
- 4. Utility Service and Information Interface t In reviewing the information exchange between GM/EMD, Western Engine Company and their customers, the inspector roted a close, effective and highly professional relationship has been established. In a previous inspection conducted at a Western Engine Company nuclear
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ORGANIZATION: WESTERN ENGINE COMPANY ITASKA, ILLINDIS s
REPORT INSPECTION RESULTS: PAGE E of F N0.: 99901079/87-01 utility customer, the maintenance engineer at the plant was asked specifically about this matter by the inspector. The inspector was advised that Western Engine Company receives all General Motors Maintenance Instructions and Power Pointers and "prescreens" them for the utility. That is, Vestern Engine Company advises the nuclear maintenance department on the details that are applicable to the utility's engine. Conversely, the naintenance engineer volunteered that he had an "open line" to Western Engine's service engineering departrents and was frequently visited by company service representatives. In summary, Western Engine Company appeared to be fully informed of all past and present GM/FMD technical issues and an interview with one of their nuclear utility clients found them fully satisfied with the quality and content of service advice.
- 5. Recent GM/EMD Turbocharger Problems In pursuing Western Engine's awareness of an ongoing product research effort within GM/EMD, the inspector found Western Engine up to date on the latest developments concerning recent problems with engine turbochargers. It appears that in varying turbocharger reduction gear ratios to obtain an optimum balance between dead load pick up, low load operation and longevity of the turbocharger, the last ratio selected (17.9:1) has experienced a problem in service. The current status of the investigation within GM/EMD shows the problem occurred in a railroad engine. At present, it is theorized that this service, with frequent gear changes as the loconotive increases and decreases speed, is the source of the problem. The inspector was advised that GM/EMD will soon positively identify railroad service application as the initiator of problems with the 17.9:1 turbocharger and that such service has no corollory to nuclear standby diesel generator service. Western Engine Company stated that a final report on the subject will soon be issued by GM/EMD.
The inspector was assured that a copy would be forthcoming to the NRC.
E. PERSONSCONTACTEDI
- L. J. Smith, Vice President and General Manaaer
- D. Norwick, Manager, General Services
- S. M. Schipitz, Manager, Ouality Assurance K. McGovern, Tool Room Supervisor C. Brenneman, Data Processing
- Attended Exit Meeting
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