ML20006D142
| ML20006D142 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20006D141 | List: |
| References | |
| REF-QA-99900779 IEIN-88-046, IEIN-88-46, NUDOCS 9002120146 | |
| Download: ML20006D142 (2) | |
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APPENDIX A Nutherm International Incorporated Docket No:
99900779/88-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on October 3-7, 1988, it appears that certain of your activities were not conducted in accordance with NRC requirements.
1.
Criterion V, " Instructions, Procedures, and Drawings," of Appendix B to 10 CFR Part 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appro)riate to the circumstances and shall be accomplished in accordance with tiese instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
u Contrary to the above, the following examples were noted where Nutherm International Incorporated (MI) either failed to prescribe a specific activity or accomplish it according to the procedures (88-01-01):
a.
A review of test procedures applicable to NI Job Number 2925 found I
non-specific acceptance criteria which could result in misinter-pretation of test data acceptability.
An example of this was found in Test Procedure TP-11 6.28, Rev. 1, L
" Function Test-Siemens RL-800 Power Circuit Breaker." This procedure requires overcurrent testing of this circuit breaker and refers to l
the manufacturer's time-current curves as the basis for determining u
acce) table trip times. These curves, a copy of which was attached L
to t1e working copy of the procedure used by the lab technician, are L
difficult to read and are subject to significant judgement so far as the limits are concerned.
In discussing this procedure with the lab technician, the lab supervisor, the QA manager, and the engineering manager, it was evident that the extrapolation of the acceptance criteria is subject to misinterpretation. Acceptance criteria should be clearly delineated so that NI QA program controls can be properly l
implemented if testing reveals out of specification conditions, b.
Engineering Test Procedure, TP-9.7.10.43, "8aseline Testing of 1
Differential Pressure Indicating Switches," requires in Step 6.7 that "as the pressure is increased in subsequent steps, record the J
pressure at which the contacts change state and setpoint, where applicable." The data sheet providing Step 6.7 was inappropriate for the circumstances in that it required recording " Set and Act" without explanation.
It was noted that the technician performing the test, l
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[.;. the Laboratory manager, the cognizant engineer and an NRC inspector each had a different interpretation of the meaning of " Set and Act."
Also. the procedure was. inappropriate in that it did not specify which pressure was to be recorded, either source pressure or the pressure of the instrument being tested.
c.
.The test result-record for TP-9.7.10.43 does not require an acceptance i
or rejection signature to signify.that the test results are either accepted or rejected.
i d.
The' pressure test was not accomplished in accordance with Procedure, TP-9.7.10.43, in that Step 4.2 required the use of a pressure monitoring device appropriate for the range of the device being tested. The device being tested was a Meriam 0-3 psi Differential Pressure Indicating Switch with an accuracy of 2 percent. The pressure monitoring device for the instrument being tested was a U.S.
t Gauge 0-30 psi instrument with an accuracy of 1 percent, five times r
a hss accurate and uncalibrated below 3 psi, and inappropriate for the application.
2.
Criterion III, " Design Control," of Appendix B to 10 CFR 50 states, in part:
" Measures shall also be established for the selection and review for suit-i.
ability of application of material, parts,. equipment, and processes that are essential to the safety-related functions of the structures,. systems and components."
Contrary to the.above, NI's program for upgrading or dedicating comercial.
grade circuit breakers for use in safety-related applications does not, in all cases, adequately evaluate material or design changes and the effect of any such changes on environmental or seismic qualification. NI's'prac-tice of. using reports.of previous qualification tests to qualify new pro-duction items is not valid because it does not account for material and i
l-design changes that may have been instituted since the qualification test
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wasperformed(88-01-02).
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