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ORGANIZATION: GENERAL ELECTRIC COMPANYPHILADELPHIA, PENNSYLVANIA.

REPORT INSPECTION lhSPECTIOldN0.: 99900219/87-01 DATES: 05/12-14, 27-28/87 ON-SITE HOURS: 30

COhhtbFUhUthLL AbbHLdd: beheral t.lecir1c L,ompanyBreaker Plant OperationsATTN: P. J. Shaffer, General Manager6901 Elmwood AvenuePhiladelphia, Pennsyvlania 19162

ORGANIZATIONAL CONTACT: J. SimpsonTELEPHONE NUMBER: 215-726-2796

huCLEAR INDUSihY ACTIV11Y: Medium voltage circuit oreakers uno switcogearenclosures.

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ASSIGtjED INSPECTOR: dh 7 cf / 57K. R. Naidu, Program Development and Reactive Date

Inspection Section (PDRIS)

(oce - 7/ 7 f/APPROVED BY:

Jam (A C. Stone, Chief, PDRIS, Vendor Inspection Branch Date

INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 21, Appendix B to 10 CFR 50.

B. SCOPE: Obtain additional information on the 10 CFR Part 21 item reportedby Arizona Nuclear Power Project, review corrective actions taken toresolve a 10 CFR Part 21 report on 4.16Kv circuit breaker and review the e

implementation of the QA program in selected areas.

~iLANTSITEAPPLICABILITY: Shoreham (50-322); P610 Verde (50-530).

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ORGANIZATION: GENERAL ELECTRIC COMPANYPHILADELPHIA, PENNSYLVANIA j-

REPORT INSPECTIONNO.- 99900219/87-01 RFSUtTS: PW 9 M 0

A. VIOLATIONS: j

INo violations were identified during this inspection.

B. N0kCONFORMANCES:.

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Contrary to 10 CFR Part 50, Appendix B, Criterion XVIII and Section XVIIIof the GE Breaker Plant Operations Quality Assurance Manual paragraph 3.2,quarterly process audits were not performed in areas other than Box BarrierAssembly and the manufacture of Rachet Wheels.

C. UNRESOLVED ITEMS:

No unresolved items were identified during this inspection.

D. INS?ECTION FINDINGS AND OTHER COMMENTS:

1. Background Information

General Electric Company (GE), Breaker Plant Operations (B|0),.

division manufactures medium voltage magna-blast circuit breakers(CB). Until approximately 1984, BP0 supplied CBs to GE, Burlington,Iowa for installation in metal clad switchgear cubicles. GEBurlinC'.on prepared Engineering Summary (ES) documents whichlisted all components assembled in the switchgear cubicle,s. TheseESs were trvisferred to BP0 beginning of 1985. During themanufacture and supply of switchgear cubicles, when componentswere substituted due to inadequate environmental qualifications,ESs were revised; h> wever, the revised ESs were inadequately jcontrolled. Obsolete copies of ESs were available at BP0 and !appeared to have been used by Arizona Nuclear Power Project (ANPP) '

to order spare parts.

2. Review of 10 CFR Part 21 Report

On November S, 1565, Arizona Nuclear Power Project (ANPP), the,

owner of Palo Verde Nuclear Generating Station (PVNGS) notified jthe NRC of a potential defect in the procurement of components j/ rom the GE Switchgear Division in Philadelphia. Specifically, !

FVNGS identified that GE was processing their Class 1E purchase |;

| orders (PO) for safety related Class 1E components as commercial j

[ grade components. This potential defect was observed during an 1

audit contiucted by ANPP's agent, Bechtel Procurement Supplier .

Quality Department (PSQD) on October 16-17, 1965. ANPP took I

timely corrective action by withholding shipments of components ;

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ORGANIZATION: GENERAL ELECTRIC COMPANYPHILADELPHIA, PENNSYLVANIA-

REPORT INSPECTIONNO.- 99900219/S7-01 RESULTS: PAGF 3 nf 4 _

1to PVNGS as appropriate. During a followup audit conducted 1

during March, 1986, ANPP/PSQD determined that the incorrect P0 jprocessing was attributed to GE neither meeting nor passing all ;

the ANPP P0 requirements to participating subvendors. Tne results |of a reaudit, performed in September 1986, by ANPP, indicated that !

GE neither implemented all the proposed corrective actions norcompleted review of all ANPP spare parts pus prior to June 1985.

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The adverse findings identified by ANPP/PSQD audits and GE's. |corrective actions to correct the adverse findings are as folif;ws:

a. BP0 personnel in Marketing and Order entry were not familiar ?

in processing Class lE component orders. Additionally, the |GE district office in Phoenix did not forward all the quality I

requirements to BP0; instead they translated ANPP P0s to ;

internal " Requisitions" and forwarded only the " Requisitions" toBPO. During the preparation of " Requisitions," the qualityrequirements were not included.

To preclude repetition of the above, the district offices-

are now required to forward the customer P0s for nuclear ;

applications to BPO. BP0 developed the following procedures: ;

QAI 108, Revision 1, dated September 16, 1986, titled, " OrderProcessing - BP0 Nuclear Switchgear Replacements." Thisprocedure outlines the requirements to process safety-relatedspare parts. The BP0 shop orders for items for safety related

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applications which are manufactured by BP0 are prefixed with 1

903. Additionally, the catalogue numbers for componentsprocured from GE subsidiaries, are suffixed with 1E. Thecatalogue numbers for items procured from other thar. GEsubsidiaries are prefixed with E. Additional codes are usedon purchase orders when Certificates of Compliance (CoC)

| are required to certify that components meet the various iapplicable IEEE standards. l

QAI 109, Revision 2, dated May 20, 1987, titled, " Nuclear cRelated Material Quality Assurance Approval." This procedureestablishes the requirements to ensure that material suppliedto BP0 is suiteble for Class 1E application, including receiptinspection of procured Class lE material during which thecomponents are inspected and verified to have CoCs.

i BP0 procedure 110 titled, " Training of Per sonnel InvolvedIn Nuclear Orders" outlines the requirements to train those

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ORGANIZATION: GENERAL ELECTRIC COMPANY'

PHILADELPHIA, PENNSYLVANIA-

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REPORT INSPECTIONNO.- 99900719/87-01 RESulTS: P AGr_.4, M Q

! individuals involved in processing nuclear orders, manufacturing,inspecting and testing safety-related components. Documentation i

on training is required to be maintained for 5 years.

Training records indicate that various personnel received Itraining on the above procedures. I

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b. ANPP determined that some of the components supplied by GE didnot have the proper certification. The following are thecontributing causes:

1) The personnel GE assigned to process ANPP P0s did not-have prior experience in processing Class 1E P0s.

2) Personnel knowledgeable in these activities were not-in the review cycle.

3) ANPP ordered some spares for circuit breakers which GEcould not supply as Class lE items. Instead, GE wouldfurnish the spare parts as components for use in Class-

lE equipment. GE stated that individual comaonents in . ,jthe 4.16kV circuit breaker (CB) or the switc1 gear cubicle I

were not qualified to IEEE 323 & 344 since GE qualifiedthe entire CB or switchgear cubicle with the CB. Therefore,-GE considers it appropriate to certify that the orderedcpare part was manufactured to the original drawings andtherefore is suitable for use in Class lE equipment.

Due to the above, either CoCs were not specified in theP0s or were shipped to GE with the component and theCoCs were misplaced. Therefore, GE was unable tosubstantiate qualification on some of the components.GE provided ANPP with a list for which GE could notsubstantiate qualification due to lack of documentation.

4) GE did not respond in a timely manner to develop writtenprocedures to correct adverse audit findings. <

GE marketing had committed to ANPP that all ANPP PCs,including those P0s initiated by Bechtel Power Corporation,agent for ANPP, would be reviewed-to determine whether GEadequately conveyed the quality requirements to theirsubvendors. GE stated that due to delays in the transferof dccuments from their Burlington plant to BP0 andmanpower shortage, they were unable to meet thecommitments in a timely manner.

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ORGANIZATION: GENERAL ELECTRIC COMPANY'

PHILADELPHIA, PENNSYLVANIA

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REPOR1 INSPECTION.'

NO.- 44000[19/87-Q RFMll TQ PW A nf o

5) GE, while centralizing their computer files to improve-their efficiency, inadvertently deleted a prefix codethat triggers a note in preparing a PC to r. subvendor torequire compliance with appropriate IEEE standards. !

c. Corrective action taken by GE BPD appears to be adequate.i BP0 has not experienced problems since they started sunplying

renewal spare parts in 1985 for complete switchgear cubiclessThe spare parts intended for ANPP are in an access controlledcrea. GE stated that ANPP intends to cancel the previous P0s .Iard issue new P0s. Pending receipt of ANPPs new P0r, GE

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intends to hold the material at BPO. !

3. Review of Purchase =0rders ,

The inspector reviewed two sets of P0s issued by ANPP that speci-I fied safety related co:nponents. The first set, distinguished

with a suffix F, was prepared by Bechtel Power Corporation (BPC)as an agent for ANFP. The second set, without a suffix waspreparea by ANPP personnel. The inspector determined thefollowing: 1

! a. The P0s required GE BP0 to supoly Class 1E components such i

as taedium voltage circuit breakers (CBs) and spare partsfor CBs which are manufactured by GE BP0, and miscellaneous '

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components such as relays, terminal blocks, etc. tMich are'

net manufactured by GE BPO. The terminology used in theP0s specifying safety-related components appears to hcVecauseo some confusion. The GE BP0's distinction between" Class 1E components" and " components for Class 1E use"was not conveyed to ANPP when the P0s were issued. Thebroad classification is discussed later in this paragraph.

b. As indicated in the ANPP's final 50.65(e) report datedJanuary 7.,1987, liarathon type short circuiting terminalboards (SCTB) were erroneously ordered in oro of the P0s.SCTBs are exclusively psed to terminate current transformers, iThe error occurred because ESs were not kept current byGE Buritngton after matcrial was revised. For instance,ESs 0269A7315 and 0269A7316 prepared in 1977 list items971 and 973 as Marathon SCTDs. On April 15, 1980, thesetwo ESs were revised deleting items 971 and 973 and adding991 and 993 specifying GE type SCTEs. Other ESs 269A 7311,7312, 7313 and 7314 were not corrected to show that GE

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ORGANIZATION: . GENERAL ELECTRIC COMPANY.

PHILADELPHIA, PENNSYLVANIA1

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REPORT INSPECTIONNn.- 9090n?19/A7-n1 RF901TS* par,F (; nf Q

| type SCTBs were furnished in the switchgear cui)icles instead;. of Marathon SCTBs. Marathon type SCTBs ere not qualified| for safety-related use, j

BP0 supplies components that they manufacture under a controlledquality assurance program as Class lE componer.s. BP0 i;uppliesprocured commercial grade components as " qualified for Class lEuse," after verification as described below. s

c. In summary, the components ordered can be broadly classifiedas follows:

1) Items manufactured at GE BP0 censisting of CBs, replacementspare components for CBs and stationary switchgear cubicles

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GE supplies CBs as Class 1E components and spare parts as .!I

l " qualified for Class 1E use." The GE certification| methodology is discussed in paragraph 4.

, 2) Items which BP0 purchases from other GE plants. Forexample, GE Neter & Control Business Department supplies irelays, terminal boards and switches. GE Sommersworth, i

located in New Hampshire, supplies current transformers. |GE Nuclear Energy Business Operations (NEBO), San Jose, y

California, supplies items such as low voltage molded case '

CBs, push buttons and transducers. Devices which arereceived with a serialized number are supplied as Class 1Edevices. Other components are supplied as " qualified for |Class 1E use." |

3) GE purchases relays and other equipment manufactured byAgastat, Brown Boveri and Westinghouse. GE requires CoCs a

for these items. Some of the manufacturers serializetheir caponents and reference the serial number in theCoC. GE supplies these components as Class lE with CoCs jto certify that they meet tie relevant IEEE standards if Iapplicable.

|4. GE Certification Methodology for Spare Parts

GE BP0 manufactures spare parts in accordance with drawings originallyused to manufacture the part. The spare part can consist of anindividual part or an assembly of a spare part and a Class lEcomponent. The following are typical examples. |'

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ORGANIZATION: GEFERAL ELECTRIC COMPANY !' PHILADELPHIA, PENNSYLVANIA

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REPORT INSPECTIONNO.* 94900?'9/A7-01 RFStH TS- PMW 7 nf 4

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a. Auxiliary switch and plunger assembly identified as part number6353570G012. GE certifies this part as " Qualified for Class 1E 4

use" component. Thi.- = ment consists of an auxiliary switchassembled on a plunger as' embly in such a rianner that when thes

CB operates, the plunger changes the state of the auxiliaryswitch contacts. The plunger assembly is manufactured by~BP0 (in accordance with original design drawing and is considered a

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commercial grade component. The auxiliary switch is procuredas a Class 1E component. After assenbling the plunger mechanismand the auxiliary switch, GE designates the entire assembly as-" Qualified for Class 1E use."

b. Rear Busing part number 0845D0124G01. . This component isone of the three rear primary disconnect bushings. BP0

, manufactures this component as a commercial grade component' and certifies it " Qualified for Class 1E Use," based on the

premisis that it was manufactured to same requirementsas the component which was installed a the switchgear whichsu::cessfully withstood the IEEE 323 & 344 qualifications.

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c. Position Switch Operator (PS0) part number 0168C3344 group 002.This component is a welded assembly which actuates a switch.The function of the switch is to indicate whether the CB isconnected or disconnected to the busbar. BP0 considers thiscomponent as a commercial. grade item and certifies that it isqualified for Class 1E use because it is manufactured inaccordance with a drawing that was originally used.to makea similar component. The similar component was used in theswitchgear assembly which successfully withstood the seismicqualification.

5. Review of 10 CFR Part 21 Report

On February 19, 1987, GE BPO notified the NRC that a AM-4.16-250-9HBtype circuit breaker (CB) failed to trip electrically at theShoreham Nuclear Power Plant, owned by Long Island Lighting Company(LILCO). The plant was in mode 5 (cold shut down). The CB powered athe "D" RHR pump motor and did not trip during surveillance testing.The CB had to be manually tripped to stop the pump motor. LILCOreported this matter as an abnormal occurrence on February 10, 1967.A weld failure in the trip crank was the cause of the failure ofthe CB to trip, The trip crank, identified as-105C9316 group oneis a linkage component between the~ armature of the shunt tripsolenoid coil and the CB trip latch. The weld that secures a pinto the trip crank failed. With this weld broken, the CB cannot be

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ORGANIZATION: GENERAL ELECTRIC COMPANY ;' - PHILADELPHIA, PENNSYLVANIA

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REPORT.

RF9t?t TS r parJ R nf 0INSPECTION

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electrically tripped and has to be manually triaped. LILC0 removedthe CS from service, disassembled the trip cranc and sent it to GE i

Philadelphia. On March 3 and 11, 1987, GE sent 4 and 10 spart trip |!cranks respectively to Shoreham. On February 11, 1987, a GE service

representative visited Shoreham and confirmed that the CB could not-be electrically tripped. The failed CB was identified to be serial (number 256A4664-012 and was manufactured in 1975 at BP0. GE devised i

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a go-no-go test procedure (TP) to inspect the integrity of the tripcrank without disassembling the breaker. On March 9, 1987, the TP i

was implemented at Shoreham to inspect the CBs. Eight of the ,!remaining 85 CBs were judged to fail the go-no-go test criteria ofthe TP were returned to GE BPO. It should be noted that failure of i

the test criteria does not necessarily indicate that the weld failed. I! Three of the eight trip cranks returned from Shoreham were subjected ;

to 10,000 cycles of operation without failure. The TP was implemented !at Turkey Point nuclear power station and no trip cranks were jrejected.

BP0 consulted a metallurgist to analyze the part failure. Fre- q

liminary results indicated that the failed trip crank was observed '

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to be bent in a direction other than the direction of the load.GE does not consider the single failure at Shoreham a generic issueand does not plan to issue a Service /.dvisory Letter at this time.GE plans to inspect an additional 100 CBs. GE proposed to inspectthe CBs at Vermont Yankee nuclear power plant in the near future.

GE BP0 stated that in 1986, Tennessee Valley Authority (TVA)contacted them on similar problems in their 4kV switchgear installedat Watts Bar nuclear power plant. BPO sent TVA 17 trip cranks. BP0did not receive the replaced trip cranks from TVA and thereforecould not determine.whether there was a problem at Watts Bar.

|1 6. Review of QA Program Implementationq

The implementation of the QA program at BP0 was verified in the |following areas:

a. A plant tour of the manufacture of CBs and switchgear cubicleassembly indicated that:

1) Parts were controlled and stored in bins which wereadequately identified.

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2) The calibration of test equipment was current.

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REPORT . INSPECTIONNO.! 99900719187-01 RESul TS * Ptt,F 4 nf Q

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3) Material for Class lE use were stored in an access I'controlled room.

4) M&terial intended for ANPP were stored in an access ,

controlled enclosure. d

E) In-process inspections were being conducted as required.

| b. Discussions with marketing and buyers indicated that'theyl were trained and knuwiedgeable in the requirements for parts| intended for nuclear power plants.!

c. In the area of audits, QA had not perforned quarterly auditsas stated in Section XVIII of their QA manual. Parkgrech 3.0states, in part, " Audits shril be performed in the followingareas: Products, processes, and systems." Paragraph 3.3states process audits shall be conducted qt:arterly to measurethe effectiveness of a manufacturing process (i.e., welding,stamping, painting, test, etc.) in meeting quality requirements..

The inspector determined that to date in 1987, only two auditswere performed: Process P8B-HB14 to manufacture "RachetWheels" was audited on April 21, 1981 and Process P12-HC47to manufacture " Box Barrier" assembly was audited un April 14,

i 1987. The inspector informed the BP0 QA manager that failure| to perform quarterly audits was a nonconformance contrary to| Criterion XVIII of Appendix B to 10 CFR 50.

(99900219/87-01-01)

E. EXIT INTERVIEW:

The inspector met with individuals mentioned in Section F and discussedthe scope and findings of the inspection.

F. PERSONS CONTACTED:

P. J. Shaffer, General Managerc

R. H. Miller, Engineering ManagerJ. Simason, Quality Assurance ManagerC. Lamaardo, Marketing ManagerE. Luggan, Mechanical Engineer.F. Broztek, Quality Assurance EngineerC Ju.cieri, Marketing

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