IR 05000267/1988008

Insp Rept 50-267/88-08 on 880321-25.Violations Noted.Major Areas Inspected:Qa Program,Implementation of 10CFR21,LER Followup & Actions on Previous Insp Findings

ML20151W643
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/19/1988
From:	Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151W616	List: IR 05000267/1988008 ML20151W611 ML20151W623
References
50-267-88-08, 50-267-88-8, NUDOCS 8805030448
Download: ML20151W643 (19)

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l APPENDIX~ 8 l

l U.S. NUCLEAR REGULATORY COMMISSION l l REGION IV NRC Inspection Report: 50-267/88-08 Operating License: DPR-34

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Docket: 50-267 Public Service Company of Colorado (PSC) I Licensee:

P.O. Box 840 ,

l Denver, Colorado 80201-0840 '

Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

l Inspection At: FSV, Platteville, Colorado Inspection Conducted: March 21-25, 1988 t Inspectors: [ 8-> u -n-P P 4< L. E. Ellershaw, Reactor Inspector, Materials Date

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and Quality Programs Section, Division of Reactor Safety fm V C ow w-s8 -?Y ;

1. Barnes, Chief Materials and Quality Date i Programs Section Division of Reactor Safety i

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s 1 Approved: be 4 1S-PV ,

I. Barnes, Chief, Materials and Quality Date l Programs Section, Division of Reactor Safety

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Inspection Sunnary l

Inspection Conducted March 21-25, 1988 (Report 50-767/88-08) l l

Areas Inspected: Routine, unannounced inspection of: (1)thelicensee's l quality assurance program including implementation in the areas of records management, document control, procurement, receiving inspection of materials and components; (2) implementation of 10 CFR Part 21 requirements; (3) licensee event report (LER) followup; and (4) actions on previous inspection finding PDR ADOCK 05000267  !

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Results: Within the four areas inspected, two violations were identified 1 (failure to control drawing revisions, paragraph 6; and failure to include or j reference applicable requirements in a purchase order for helium circulator 1 refurbishment parts, paragraph 7). Two unresolved items are identified in paragraph :

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! Persons Contacted

• F. J. Borst, Nuclear Training Manager

• P. F. Tomlinson, Manager, Quality Assurance Division (QAD)

• Heggen, Supervisor, Engineering Suppor * Sargent, Assistant to Vice President, Nuclear Operations

• I. LeBianc, Nuclear Engineering Services Manager

• H. Fuller, Manager, Nuclear Production .

• Block, Superintendent, Nuclear Betterment .  ;

• G. Seymour, Quality Assurance (QA) Engineer

• M. Lehr, Supervisor, QA Engineering

• R. Sutton,. Supervisor, QA Auditing

• P F. Moore, Supervisor, QA Technical Support .

• Seed, Nuclear Engineering Division (NED) Site Engineer '

• Blanchard, Supervisor, Records

' L. Brey, Manager, Nuclear Licensing & Fuels .

• L. D. Scott, QA Services Manager

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• E. Niehoff, Nuclear Design Manager

• W. Cappello, Superintendent, Planning / Scheduling / Stores

• F. Novachek, Technical / Administrative Services Manager .

• J. M. Granling, Supervisor, Nuclear Licensing - Operations  !

4 *A. H. Wong, Senior Nuclear Licensing Engineer

• D. Johnson, NED Site Supervisor

• T. D. McIr; tire, NED Site Supervisor l

• B. Doyle, QA Engineer D. Warembourg, Manager, NED M. J. Ferris, QA Operations Manager R. L. Craun, NED Site Manager The NRC inspectors also interviewed other licensee personnel during the course of the inspectio l * Denotes those persons who attended the exit intervie . Actions on Previously Identified Inspection Findings (92702, 92701) (Closed) Violation (267/8515-01): Release of control rod cable assemblies by receiving inspection without identifying a "hold"  !

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status in regard to nonreceipt of purchase order required fe+igue  ;

test data, i

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The NRC inspector reviewed the applicable nonconformance report-(NCR), NCR 85-718, which was issued as a result of this inspection finding and the fatigue test data that was subsequently received from GA Technologies and included in Change Notice (CN)

1933, Revision K. No problems or questions were noted in regard to this data. Review of the procurement program during this inspection (see paragraphs 7 and 8 below) identified no additional discrepancies

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with respect to the receiving inspection functio This violation is closed, (Closed) Open Item (267/8515-02): Corrosion susceptibility of Inconel 625 control rod cable wire to molybdenum disulfide surface fil The NRC inspector reviewed GA Technologies Document No. 907877, "Test Report.on Sulfate from MoS 2 0xidation," issue date May 16, 198 Included in this document were the results of experiments conducted to measure the quantity of sulfate ions produced from oxidation of

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molybdenum disulfide coatings on control rod cable wire-(original l Type 347 stainless steel wire and replacement Inconel 625 wire) by water vapor. The increased acidity of the sulfate solutions obtained in these experiments suggested that the sulfate was derived from sulfuric aci The amount of sulfate produced on the replacement Inconel 625 wire was approximately 10 percent of that formed on the original Type 347 stainless steel wire. In'that chloride induced transgranular stress corrosion cracking was the identified corrosion mechanism on the original Type 347 stainless steel control rod cable wires with general corrosion not being a significant factor, it was concluded that the replacement Inconel 625 cable wires would not be degraded by general corrosion caused by sulfuric acid formation.

l This view was further substantiated by literature review of studies perform d on corrosion rates of Type 304 stainless steel and I ;ot 'S in sulfuric acid solutions. These studies showed that ct. rror by sulfuric acid of the austenitic stainless steel was 20 to 50 '.mes higher than the Inconel 625 material. The NRC inspector concurred with the conclusions, draw This item is close (Closed) Open Item (267/8515-03): Acceptability of Inconel 625 control rod cable wire as a result of use of Apex SP 2 drawing ;

compound (containing 0.26 percent by weight chlorides) in final wire l reductio l l

i An analysis was performed by GA Technologies of water used to leach

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two separate samples of the Inconel 625 wire. The results obtained l

were less than 10 percent of the GA Tecanologies acceptance criteria for chloride contamination of reactor components. This item is close . LER Followup (92700)

During this inspection, a followup was made in regard to LER 85-002. This LER pertained to stress corrosion cracking of helium circulator bolting which was initially identified as a result of the failure :f 1 of  ;

24 primary closure bolts (which secure the bearing asse.Tbly' of th '

compressor rotor to the helium circulator unit) during reinsta?lation l

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following refurbishment of circulator C-2102. Chemical aaalysis of the C-2102 primary closure bolts indicated the presence of high levels of l

chloride and sulfate on the bolt surfaces.

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-5-The NRC inspector reviewed the LER with respect to the results of metallographic examinations performed on three types of circulator bolting; i.e., primary closure (90 C2101-300-40), stator hold-down (90 C2101-380-10), and duct hold-down (90 C2101-340-9). From this review,

, it was ascertained that stress corrosion cracking was found in primary closure bolting for 4 of the 5 circulator The numbers of bolts found to contain cracks in samples of seven bolts from Circulator C-2101 and six bolts from each of the other circulaters were one from Circulator C-2101, three from Circulator C-2102, one from Circulator C-2103, one from Circulator C-2104, and two from Circulator C-2105. Stator hold-down bolts from Circulators C-2101 and C-2102 were also found to exhibit stress corrosion cracking (four in a ample of six, each circulator) with the sample bolts from the other circulators showing no evidence of crackin None of the duct hold-down bolting examined showed evidence of stress corrosion crackin The NRC inspector reviewed the following documents with respect to origins and potential effects of chlorides on helium circulators:

GA Technologies Document No. 907838, "An Investigation Into The Source of Chloride in the Fort St. Vrain Primary Circuit," issue date March 5, 1985; GA Technologies Document No. P07875, "Evaluation of Fort St. Vrain Metallic Components Exposed to Primary Coolant Chloride Contamination," issue date March 21, 1985; and GA Technologies Document No. 908818, "FSV Stress Corrosion Report,"

issue date April 10, 198 The NRC inspector agreed with the assessments contained in these documents and with the rationale for chloride induced stress corrosion cracking being the operative failure mechanism for the high strength primary closure and stator hold-down bolt LER 85-002 identified that all primary closure bolts, stator hold-down bolts, and duct hold-down bolts had been replaced with Inconel 718 bolt This high strength nickel base alloy is generally considared to be significantly more resistant to initiation of chloride induced stress corrosion cracking than high strength ferritic and austenitic stainless steels. The NRC inspector confirmed by review of PSC Purchase Orders (P0s) N5593 and N5997, GA Technologies travelers and material P0s, and applicable vendor certified material test reports (CMTRs), that the above three types of bolts had been replaced with Inconel 718 bolting by GA Technologies for Circulators C-2102 and C-2104. Similarly, replacement of these bolts with Incone 718 material in Circulators C-2101, C-2103, and C-2105, was verified to have been accomplished by PSC by review of controlled work procedures, bill of materials and CMTRs, and Maintenance Procedure MP-21-18, "Helium Circulator Compressor Assembly Retaining Bolt Replacement," effective date April 13, 1985.

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-6-No violations or deviations were identified in this area of inspectio .

This LER is considered close , Quality' Assurance (QA) Program Annual Review (35701)-

The purpose of this area of the inspection was to verify that the licensee is implementing a QA program that is in conformance with the technical '

specification (TS), Appendix B to 10 CFR Part 50, Appendix B of the Updated Final Safety Analysis Report'(UFSAR), and industry standards and guides. The current edition of the UFSAR is Revision 5 and was submitted to the NRC on July 22, 1987. Review of the TS and the UFSAR indicated that changes had been made to both documents ~since the last inspection in this area (NRC Inspection Report 50-267/86-32), with significant changes -

occurring in terms of QA staffing. At the time of the last NRC ,

inspection, there were 55 people in the QAD including.1 supervisor and 3 '

auditors in the QA Audit Section. There was a total of 69 people in the QAD at the time of this inspection, including 1 supervisor and 7 auditors ,

in the QA Audit Section, with open requisitions for 2 more auditor l Discussions with the manager of the QAD revealed that a total of 75 people  ;

are currently authorized for the QAD function. The NRC in pector reviewed the auditor qualification and training procedures and records relative to the commitments contained in FSV TS AC 7.1.3, Section 8.C(2) and implemented by Administrative Procedures Manual (APM) Procedure G-7, "FSV Project Personnel Training and Qualifications Programs," issue 17 dated August 10, 1987. These commitments were established in order to satisfy the requirements of ANSI N18.1-1971. It was determined that these commitments adequately describe the requirements to support a QAD personnel (auditors) training and qualification program. A review of the lead auditor and auditors training and qualification records indicated that the QAD program has been implemented and is in compliance with the commitments of the TS and APM G- I No violations or deviations were identified in this area of the 1 inspection. The results of inspection of implementation of the QA program i

are discussed in paragraphs 5, 6, 7, and 8 belo i Records Program (39701)

l This area of the inspection was conducted to assure that the licensee has established and implemented a records program which is in conformance with UFSAR commitment Section B.5.17 in the UFSAR addresses the FSV operational records system; records content; and records accumulation, identification, and retentio The implementing procedure is APM Q-17,

"Quality Records," issue 11 dated March 26, 198 At the time the NRC inspector was attempting to determine the identity of the implementing procedures, and during discussions with QAD personnel, it was revealed that the QA audit section had recently performed an audit of the records program. This audit was performed during February 1988 and was documented in a QA audit report identified as RCON-88-01, "Records Control."

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-7-The NRC inspector reviewed the audit report and determined it to be a very l

comprehensive and in-depth effort. As a result of the audit, two Corrective Action Reports (CARS) were issued. CAR-88-002 identifies

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discrepant conditions pertaining to the records program and concludes that: (a) the program does not establish _or define organizational structure or authority; (b) the applicable procedures do not provide a plan for implementation; and (c) the program does not provide.or clearly define what constitutes a QA record, a lifetime record, or a nonpermanent record. CAR-88-003 identifies discrepant conditions pertaining to the records storage facility and concludes that: (a) security alarms. do not exist on the rear doors, (b) the facility does not meet the 4-hour minimum fire rating requirements of ANSI N45.2.9-1974 and the UFSAR, (c) unauthorized personnel access is uncontrolled, and (d) control and protection of quality records maintained in temporary storage by the originating organization prior to transmittal to the Record Center are not addressed in the records control progra Certain of these records have an annual transmittal frequenc ,

Because of_the far reaching conclusions of the audit and what would appear to be a necessarily extensive corrective action effort, the NRC inspector concluded that further inspection of this area would not add anything  !

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further to that which had already been identified. The identified

j conditions are considered to be an open item pending NRC review of the licensee's resolution and implementation of specified corrective actions

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(267/8808-03). Document Control (39702)

The NRC inspector reviewed the documents listed below in order to verify that administrative controls exist and that they provide measures to assure that documents are controlled in accordance with the commitments of the TS, UFSAR, and regulatory requirement Document N Revision Date Title APM G-9 7 02/15/87 Controlled Work Procedure APM G-10 6 12/04/86 Data Management-APM Q-6 6' 12/31/86 Document Control SMAP-18 4 11/19/87 Processing of Temporary Configuration Reports i

ED-100 4 '02/25/88 CN Preparation and Document Control Document N Revision Date Title ENG-1 13 02/25/88 Control of Modification and Documentation Changes

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-8-The NRC inspector selected ten Piping and Instrumentation (P&I) drawings to verify that the latest revisions had been distributed to the designated locations within the plant. The latest revision to a drawing was determined by review of the applicable aperture card which was maintained in the Records Center. The designated locations for the distribution of drawings were specified in the FSV Document Distribution Handbook (DDH).

The current revision status of the P&I drawings, as determined by review of the aperture cards, was as follows:

Drawing N Revision 11-2 S 14 AA 21-5 Bi 21-9 DC 22-7 BV 22-8 BP 25-2 AF 46-4 AW 61 AE The DDH dated March 1, 1988, identified 12 controlled sets of "Halfsize" P&I drawings which must be distribute The NRC inspector selected the following controlled setri, each of which had its specified location:  !

Controlled Set N Location 2-1 Maintenance Shop 4-1 Results Shop 5-1 Control Room 5-50 * Plant Stick Files

• Note: The Plant Stick Files encompass numerous locations in the reactor 1 and turbine buildings. Not all of the drawings are required at each of I the locations. The Records Supervisor provided a list which showed the P&I Plant Stick Files locations and specified which of the P&I drawings were to be distributed at each locatio In addition, Procedure ENG-1 required all applicable controlled design documents to be stamped with the following: "Caution, this document has been changed by the following .

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This caution stamp method is used to call the user's attention to the fact that an approved Change Notice (CN) or a Document Change Notice (DCN) affects the particular document, but has not yet been incorporate This is to be done in a subsequent revision.

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Review of each of the drawings at the specified locations revealed that Drawing No. 14 was the only one that did not exhibit inconsistencies. The discrepancies observed in the other nine were as follows:

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-9- Drawing No. 11-2: The copy in the control room was Revision S, while the copies in the results shop, maintenance shop, and Level 10 in the reactor building were all Revision R-1. The date of Revision S is January 10, 198 Drawing No. 21-5: The copy in the control room was Revision BT, while the copy at Level 1 in the reactor building was Revision B The date of Revision BT is January 25, 198 Drawing No. 21-8: All revisions at all locations were CV. However, the control room copy was caution stamped and five Temporary ,

Configuration Report (TCR) numbers had.been entered. Note:

Procedure SMAP-18 identifies TCRs as Temporary Configuration Reports while ED-100 identifies TCRs as. Temporary Change Reports. The copies of the drawing located in the results shop, maintenance shop, and :

Levels 2 and 3 in the reactor building were not caution stamped. The copy located at Level 1 in the reactor building was caution stamped and had CN or DCN No. 2083 entere !

) Drawing No. 21-9: All revisions at all locations were DC. However, l the control room copy was caution stamped with four TCR numbers and DCN 44 entered. The results shop copy was caution stamped with a CN or DCN No. 2083 entered. The maintenance shop copy was caution stamped with DCN 44 and 2083 entered. The reactor building copies l located at Levels 1, 2, and 3 were all caution stamped with DCN 44 I entere Drawing No. 22-7: The control room copy was Revision BV while the copies in the results shop, maintenance shop, reactor building Levels 2 and 3, and the turbine building Level 6, were all Revision BU. Revision BV is dated January 27, 1988. In addition, the control room copy had three caution stamps with the following numbers entered: Two RR numbers (the NRC inspector could not ;

ascertain what the acronym RR meant), CN or DCN Nos. 2719 and 2537 !

The copies in the results shop and maintenance shop were caution i stamped and had DCN 59 and 2719 entered. The copies'at Level 2 and 3 in the reactor building were caution stamped with DCN 59 entere Drawing No. 22-8: The copies located in the control room, maintenance shop, results shop, Levels 2, 3, and 4 in the reactor building, and Level 6 in the turbine building were all Revision B ;

However, the aperture card for this drawing showed that the latest applicable revision was BP, which was dated January 28, 1988. In addition, the control room copy was caution stamped and had three TCR numbers and DCN 59 entered. All copies at the other locations were caution stamped and had DCN 59 entere Drawing No. 25-2: The control room copy was Revision AF dated February 2, 1988. lhe copies located at the results shop and maintenance shop were Revision AE. Also, the control room copy was

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--10-caution stamped with CN or DCN No. 2109 entered. The AE revisions were caution stamped with DCN 59 and 1550 entere Drawing No. 46-4: The control room copy was Revision AW dated February 5,1988, while the copies located at the results shop and maintenance shop were Revision AV. The control room copy was caution stamped with CN or DCN No. 2109 and 2085 entered, while the results shop and maintenance shop copies were caution stamped with DCN 59 and 2085 entere Drawing No. 61: All revisions were AE. However, the control room and results shop copies were caution stamped with DCN 59 entere The copies located in the maintenance shop, and Levels 1, 3, 4, 5, and 6 in the reactor building were caution stamped and had DCN 59 and 2104 entere These conditions of failing to: (1) distribute the latest revised drawing to the applicable locations, (2) keep all designated locations current with the latest revision, and (3) identify all applicable 1CR/DCN/CN numbers on the drawings, constitute a violation of Criterion VI of Appendix B to 10 CFR Part 50 requirements and the licensee's approved quality assurance program (267/8808-01).

7. Procurement Program (38701)

The objective of this area of inspection was to ascertain whether the licensee is implementing a QA program to control procurement activities that is in conformance with regulatory requirements and licensee commitment Program Review: The NRC inspector reviewed the documents listed below to verify that administrative controls exist and that they provide measures to assure that necessary technical and quality requirements are included in procerement documents for safety-related items or services. The documents were also reviewed to verify that controls exist for the selection, approval, and use of vendor Document N Effective Date Title APM Procedure Q-2, 11/7/86 Quality Assurance Program Issue 6 APM Frocedure Q-4, 02/29/88 Procurement System Issue 10 ENG-16, Issue 3 01/05/87 NED Procurement Document Evaluation MPRM-10, Issue 7 08/25/87 Review of Safety-Related i

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-11-Purchases MPRM-11, Issue 9 03/07/88 Supplier _ Qualification Procedure

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(1) Commercial Quality Classification: During review of Procedure ENG-16, Issue 3, the NRC inspector noted that the procedure permitted utilization of vendors who would not accept the applicability of 10 CFR Part 21 as a purchase order requirement. This approval appeared, however, to be restricted by the procedure to only procurement of commercial grade item The criteria used to define commercial grade items in this procedure was fully consistent with that of 10 CFR Part 2 While this approach would not appear to conflict with the requirements of 10 CFR Part 21, the NRC inspector noted from review of the current Approved Vendor List that those vendors who would not accept 10 CFR Part 21 as a procurement requirement included vendor types (e.g., calibration services) for which there could be a potential question as to whether they are furnishing a commercial grade item as defined by the regulatio This subject is considered an open item pending additional NRC review (267/8808-04).

(2) Establishment of Technical'and Quality Requirements in Procurement Documents: During review of Procedure ENG-16,.

Issue 3, the NRC inspector also perceived a lack of clear guidance with respect to establishment of applicable vendor technical and quality documentation requirements for specific ,

procurements. Specifically, although the procedure provided a source list of reference documents for reviewers to utilize, the NRC inspector could not clearly discern what were the-governing criteria for selection of applicable procurement requirement clauses contained in Attachment ENG-16B of this procedure. A discussed in paragraph 7.b(2) below, one example of a lack of consistency in establishment of procurement requirements was I noted during inspection of implementation of procurement controls. This subject is considered unresolved pending ,

licensee evaluation and additional NRC review (267/8808-05). l Similarly, although general criteria were contained in Attachment ENG-16E of this' procedure with respect to dedication l of commercial grade components, Attachment ENG-16A (i.e., l baseline checklist used to establish technical and quality '

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-1P-requirements) of this procedure did not appear to be structured to provide for a clear record of the engineering evaluation of component critical parameters and bases for dedication. A draft version of Issue 4 for ENG-16.was provided to the NRC inspector which showed significant improvements in this regard. This subject is considered unresolved pending issue of the later procedure revision and further NRC inspection of the dedication process (267/8808-06). Program Implementation: -

(1) Refurbishment of Helium Circulators: Helium Circulator C-2101 was removed from service in July 1987 as a result of excessive shaft wobble indications and a purified helium interspace lea It was determined from metallurgical analysis'of C-2101 components that damage to the circulator had occurred as a result of component failures resulting from caustic stress corrosion cracking. A common environment to all the failed and damaged components was steam utilized for the turbine drive. As )

a result of this damage to Circulator C-2101, design changes were made to the circulators which included selection of an alternate material that is more resistant to caustic stress corrosion cracking for certain of the boltin The NRC inspector reviewed those purchase orders (P0s) that had l been placed with GA Technologies which were applicable to the l planned circulator refurbishment activities; i.e., P0s N6290, I N6694, N8157, N8194, N8548, and N844 Each of the P0s imposed 10 CFR Part 21 and required certification of conformance to the requirements of the applicable drawirgs and to the requirements of the PSC approved GA Technologies QA Manual. On review of the drawings referenced by the P0s, the NRC inspector noted that the drawings did not, in general, reflect current material and examination requirements. The NRC inspector was informed that the drawings would be revised upon completion of CH2715, which was stated to be in process at GA Technologie Of particular concern to the NRC inspector was P0 N8446 dated December 4,1987, which included fasteners for which changes in i material had been made as a result of the identified C-2101 !

caustic stress corrosion cracking. The reason for concern was i that this P0 had not been revised to be consistent with PSC engineering report "Report of Helium Circulator S/N C-2101 and Inlet Piping S/N 2001 Repair and Modification Activities," which was transmitted to the NRC by PSC Letter P-88019 dated January 22, 1988. Section 6.0 of this report contained detailed QA requirements for circulator fasteners which were committed to be implemented for all circulator fastener procurement The NRC inspector was informed by PSC personnel that these requirements were incorporated in GA Technologies procurement i

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-13-document Copies of these documents were not available, however, on site for the NRC inspector to revie Paragraph 3.1 of APM Procedure Q-4, Issue 10, requires that a procurement package include technical and QA requirements, and other requirements necessary to establish quality of procured material Changes to technical or QA requirements contained in procurement documents are required by paragraph 3.4 of this procedure to be accomplished by a revision to the document. The failure of PSC to incorporate current QA requirements in this P0 is an apparent violation of Criterion IV of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program (267/8808-02).

(2) Additional Procurement Sample: The NRC inspector reviewed the following two P0s for commercial quality classification items:

P0 N8598 - 1/4 in., 6000 lb., stainless steel ball tip valve; and

P0 N7990 - welding materials (ASME SFA 5.11, E NiCRFe-3 electrodes; ASME SFA 5.20, E 71T-1 wire; and ASME SFA 5.29, E91T-B3 wire).

The NRC inspector noted that a PSC approved QA program had been l invoked on both P0s and that the vendors were required to obtain PSC '

approval of any nonconformances that had been dispositioned repair, rework, or accept-as-is. With respect to P0 N8598, the completed l Attachment ENG-16A checklist did not provide a clear documented basis i for dedication (see discussion in paragraph 7.a(2) above); i.e., ;

dedication was indicated to be based on satisfactory completion of l normal receipt inspection and documentation review, without '

discussion of critical valve parameters or elaboration that i dedication was being apparently based on satisfactory hydrostatic and i seat leakage test result l During review of P0 N7990, the NRC inspector noted that the P0 required only chemical analysis to be provided and did not require the vendor to furnish mechanical test data in accordance with the requirements of the materials specifications. The NRC inspector was unable to establish both the reasons for this approach to procurement and whether any formal engineering specification requirements existed with respect to welding matt als. It was additionally noted during this inspection, as discussed below, that other welding materials had been procured for which full nachanical test and chemical analysis requirements had been imposed on vendors. As noted in paragraph 7.a(2), the NRC inspector considers this lack of consistency in establishing procurement requirements to be an example of a result of absence of governing criteria regarding selection of procurement requirement clause . . l

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l-14- 1 The NRC inspector reviewed the following three P0s for Q l safety-related materials: l N 8091 -

E7018 electrodes, N 5586 -

SFA 5.29, E91T1-B3 wire; and i

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ASTM A193 Grade B7 studs All of the P0s invoked PSC approved QA programs and, in the case of the welding material P0s, required mechanical test data and chemical analysis in accordance with the requirements of the material specification No violations or deviations were identified in this area of inspectio GA Technologies Quality Level Issues: During an audit performed at l GA Technologies on January 11-15, 1988, PSC identified that a circulator pelton wheel had been procured by GA Technologies as a Quality Level (QAL) II item. The GA Technologies definition of QAL II is "Any nonsafety-related system, structure, subsystem, or item, which as a result of failure, could cause an unscheduled reduction in required performanc ASME Code Section I,Section IV, and Section VIII, Division 1 and 2 items; and ANSI B31.1 items shall be classified as QAL II." The PSC requirements for the pelton wheel were that the item was to be furnished in accordance with the GA Technologies QA program, with the intent that GA Technologies apply appropriate procurement requirements for safety related component The audit additionally established that the GA Technologies design document for the pelton wheel identified that it performed a safety-related functio The root causes for this problem were established to be: (1) the PSC procurement system did not recognize GA Technologies graded procurement system, and (2) GA Technologies inappropriately procured the pelton wheel to a QAL II requirement. This procurement action was identified to the NRC as a potential 10 CFR Part 21 item and was subsequently evaluated by PSC to be not reportabl (1) Review of Pelton Wheel P0: The NRC inspector reviewed GA Technologies P0 061820 dated March 28, 1986, for the supply of two QAL II pelton wheels. From this review, it was ascertained that the P0 had invoked a QC program (ASQC-STD-CL, " Quality Control Requirements") on the vendor and required prior GA Technologies approval of vendor procedures for fluorescent penetrant examination, ,

ultrasonic examination, shot peening, ar.d heat treatment. In addition, procurement requirements included source inspection of I material ultrasonic examination, component liquid penetrant l examination, final inspection, and documentation review. Heat treated specimens were also required to be furnished for each par ,

Vendor documentation submittals included a certificate of conformance '

to procurement requirements, mechanical and chemical test results for materials used, special process personnel qualification requirements j and certification of compliance with specification requirements, heat ,

treat records, nondestructive examination reports, and penetrant !

materials analysi j l

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-15-As a result of review of the above requirements, the NRC inspector concluded that misclassification of the pelton wheels as QAL II items did not revist in an identifiable reduction in the level of assurance

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of prode:.t. quality. The NRC. inspector accordingly concurred with the l

results of the PSC evaluation for 10 CFR Part 21 reportability.

l (2) Status of Component QAL Classification and Review of Other Vendor QA Programs: PSC personnel informed the NRC inspector that all

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circulator parts (except diffuser and stop valve) have now been I

classified as QAL I (safety-related) or QAL II. Agreement on the classifications with GA Technologies was indicated to be close, with the final classifications to be formally transmitted to GA Technologie Six items (in the current procurement activities for i circulator and tail pipe refurbishment) have been identified where the Qf._ classification used by GA Technologies for procurement differs from the PSC classification. Similar procurement classification and review efforts are still in progress with respect to procurement packages for_ control rod drives and moisture monitor A final report on these issues is expected to be completed in i mid-1988. This subject is considered to be an open item pending NRC l review of the final report during the scheduled 1988 outage 1 (267/8808-07). J A review has been completed by PSC QA of QA manuals for all PSC )

approved vendors. From this review, it was established that three other vendors had multi-level QA programs and, thus, the PSC practice of simply invoking the accepted vendor QA program in P0s could have led to similar problems to that identified in procurement from GA Technologie Actual usage, however, of two of these vendors, (Cooperheat, heat treat services; Protopower, design services) was for the vendor to perform work in accordance with PSC procedure The third vendor's QA program (Weed Instrument) had been properly classified on the Approved Vendor List for furnishings of safety-related equipment and services. To preclude recurrence of this problem, PSC has revised Procedure MPRM-11, "Supplier Qualification Procedure," in Issue 9 to require the PSC auditor to

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specifically identify if a company has a multi-level QA program and, l if so, place a restriction on the PSC. Approved Vendor List to assure j that the proper level of the QA program is used in procurement.

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No violations or deviations were identified in this area of inspectio . Receipt, Storage, and Handling of Equipment and Materials (38702)

The objective of this area of inspection was to ascertain whether the licensee is implementing a QA program to control receipt, storage, and handling'of equipment and materials that is in conformance with regulatory requirements and licensee commitments.

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-16-a.' Program Review: The NRC inspector reviewed the documents listed below to verify that administrative controls exist and that they provide appropriate measures to assure that received materials and equipment are examined for damage and conformance to procurement document requirements. The review was also performed to verify that responsibilities are defined, acceptance criteria established, documentation requirements for performance of receipt inspections delineated, and that controls exist with respect to nonconforming items and storage of safety-related item Document N Effective Date Title APM Procedure Q-2, 11/07/86 Quality Assurance Program Issue 6 APM Procedure Q-4, 02/29/88 Procurement System Issue 10 '

APH Procedure Q-7, 06/11/87 Control of Procured

. Issue 10 Materials, Equipment, and Services APM Procedure Q-8, 09/30/86 Identification and Control Issue 7 of Materials, Parts, and Components APM Procedure Q-15, 03/15/88 Nonconformance Reports Issue 7 MRIM-1, Issue 10 12/08/87 General Receiving Inspection *

SMAP-28, Issue 3 02/12/88 Station Shelf Life Program As a result of this review, the NRC inspector determined that-the documented program provides satisfactory controls and guidance for performance of the receipt inspection function, documentation of results, control of shelf life materials, and segregation and control of nonconforming item The NRC inspection did note during inspection of implementation of this program that the program appeared to rely, to some extent, on the knowledge of the receiving inspector. This observation was prompted by review of receiving i inspection records for valves purchased on PO N8598 (see paragraph 7.b(2). The P0 denoted applicable procedures for pressure testing of the valves, without delineating the specific acceptance criteria for the type of valves ordered. To determine the adequacy of the vendor test documentation the receiving inspector had to review the vendor catalog and procedures to establish that correct test values had been use The NRC inspector informed licensee personnel of this observation at the exit intervie l l

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-17- Program Implementation: In order to assess implementation of the receipt inspection program, the NRC inspector reviewed procurement packages (purchase order, engineering review, QA reviews, receiving inspection report, vendor documentation) for the items identified in paragraph 7.b(2). Similar reviews were performed for two recently received shipments; i.e., P0 N8651, A 500 grade structural steel; P0 N8615, Hysol EA 929NA expoxy adhesiv The NRC inspector determined that receipt inspection had been effectively performed with respect to procurement requirements. The NRC inspector reviewed the practices used in receipt inspection to identify and segregate nonconforming item Three open NCRs were randomly selected from a computerized status list and the items examined. Each item was properly tagged as nonconforming, was identified to P0, and was maintained on shelving with other items that had open NCR The NRC inspector visited the stores areas to assess storage conditions, control of material identity, and control of shelf life materials. In general, the storage conditions appeared to be good with material tagged as to identity and applicable P0. The NRC

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l inspector verified identification and traceability to procurement '

documentation of P0s N8091, N5586, and N4993 Additionally, the NRC inspector randomly selected two items (Stock No. 1710936, Buna N plug; Stock No. 1724540, seal) from a computerized listing of shelf life materials and verified that the items were properly tagged with P0 and shelf life expiration date. During this review, the NRC inspector also checked that the P0 N8615 epoxy, referenced above, was l identified with a shelf life expiration date that was consistent with vendor recommendations for the storage temperature being use As a result of the above inspection, the NRC inspector determined l that the program for receipt inspection, storage, and control of l nonconforming items identified during receipt inspection, appears to '

be effective with respect to the committed objective No violations or deviations were identified in this area of inspectio , 10 CFR Part 21 Inspection (36100)

The purpose of this inspection was to determine whether the licensee had i established and implemented procedures and controls which provide for i evaluating deviations, assuring that defects or failures to comply are '

reported to the NRC, and that records applicable to these activities are established and maintaine The following procedures applicable to 10 CFR Part 21 were reviewed:

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DPM G-8 6 01-27-87 Compliance with 10 CFR 21 Requirements

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e-18-TSP-12 3 08-19-87 Evaluation and Imple-mentation of Compliance with 10 CFR 21 TSP-28 3 12-26-86 Conduct of Technical Services Reviews for the ,

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Operating Information Assessment Group (0IAG)

MPRM-6 2 01-15-87 Review of IE Notices / i Bulletins NPAP-1 4 02-02-88 Fort St. Vrain Nuclear Generating Station Operation Information Assessment Group Charte The NRC inspector determined that the posting, evaluating, and reportin +

requirements of 10 CFR Part 21 were clearly established in the above referenced procedures. However, the procedures were not clear with respect to the establishment and maintenance of records associated with 10 CFR Part 21 activities. The two procedures directly related to 10 CFR ,

Part 21 (APM G-8 and TSP-12) do not address record requirements while TSP-28, which does not address 10 CFR Part 21, most clearly addresses records, closecut packages, and submittal to record storage. The other procedures are more generic in nature and do not specify 10 CFR Part 2 ;

The NRC inspector reviewed NRC Inspection Report 50-267/87-05 with respect to licensee action on 10 CFR Part 21 reports. From this review, the NRC inspector established that the licensee had been presented with eight

10 CFR Part 21 reports during that inspection and had been able to close three by virtue of their not being applicable. The status of the  !

remaining five was reviewed during this inspection to determine the  ;

effectiveness of the licensee's procedural implementation. Three of the l five were deemed not applicable. However, the other two which are  !

identified as R87-003 and R86-013 remain open. Review of the l documentation packages associated with each, revealed that Action Requests '

had been issued to the Nuclear Engineering Division (NED) in April 1987, in order to assess potential impact. At the time of this inspection, NED had not responde The NRC inspector expressed concern over what appeared i to be a lack of timeliness in responding to the Action Request The NRC inspector was informed at this time that the QAD Audit Section had recently performed an internal audit with respect to 10 CFR Part 21 implementation, which resulted in ,he issuance of CAR 88-004 dated l March 3, 1988. The CAR identified that several 10 CFR Part 21 reports had been received prior to February 1587.in which, while certain actions have occurred, the associated Action Requests still remain open. While it did  ;

not specifically address the subject of records, the recommended '

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-19-i corrective action dealt with the establishment of programmatic controls to i assure that reports would be promptly identified, evaluated, and resolve Discussions with cognizant licensee personnel indicated that the~

identified records concern and the apparent lack of timeliness are.being addressed and will result in the resolution of these concerns.. These conditions are considered to be an open item pending the-licensee's-resolution and implementation of specified corrective actions (267/8808-08).

1 Unresolved Item Unresolved items are. matters about which more information is required in order to ascertain whether or not the items are acceptable, violations, or deviations. The following unresolved items were discussed in this report:

Paragraph Item Subject 7 267/8808-05 Establishment of technic'al'

and quality requirements in procurement document 7 267/8808-06 Dedication of commercial grade items 1 Exit Interview An exit interview was conducted on March 25, 1988, with the licensee personnel denoted in paragraph.1. At this time, the NRC inspectors reviewed the scope and findings of the inspectio ' I