IR 05000397/1989028
| ML17285A818 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/06/1989 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A817 | List: |
| References | |
| 50-397-89-28, NUDOCS 8910310040 | |
| Download: ML17285A818 (14) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No. 50-397/89-28 Docket No. 50-397 License No.
NPF-21 Licensee:
Washington Public Power Supply System P. 0.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear project No.
(WNP-2)
Inspection at:
WHP-2, Benton County, Washington Inspection Conducted:
September 11-14, 1989 Inspectors:
W. Wagner, Reactor Inspector R. Wilson, Vendor Inspection Branch, NRR ro r./Z Approved by:
tlon ate signed
~Suaraar:
Ins ection Durin the Period of Se tember 11-14, 1989 Re ort Ho. 50-397/89-28 uey, C se, Engsn Results:
General Conclusions:
~A<<:
i p
f Il O<ng several examples wherein the, licensee had not properly dedicated commercial grade items for safety-related applications.
0 en Items Summar
Hone a9ioaioOno e9loi~
PDR ADOCK 05000397
PNU
DETAILS 1.
Persons Contacted Licensee
- J P
- C. M.
- G. C.
- L. T.
- R. L.
- M. E.
- C. H.
- R. E.
- S. H.
- G. H.
- R. L.
- J
- M. C.
Burn, Director of Engineering Powers, Plant Manager Sorensen, Regulatory Programs Manager Harrold, Manager, Generation Engineering Koenigs, Technical Manager Etchamendy, Manager, Materials McGilton, Plant Operational Assurance Programs, Manager Partrick, Plant Administration Manager (Acting)
Peck, Spare Parts Engineering Manager Wooley, Plant Procurement Quality Assurance Manager Webring, Plant Maintenance, Assistant Manager Person, Engineer, Spare Parts Engineering Bartlett, Procurement QA Engineer Bonneville Power Administration
- D. L. Williams, Nuclear Engineer
- Attended the Exit Meeting on September 14, 1989.
In addition to the personnel annotated above, the following NRC personnel attended the exit meeting:
~d'O<k materials engineer (faxed to the licensee on July 10, 1989) the inspectors noted that the referenced document was not an audit, on y memorandum of discussion with two UL personnel, and'did not encompass witnessing of testing or review of procedures.
The inspectors considered that licensee conclusions based on this memorandum appeared to be superficial and poorly substantiated.
S ce files provided for NRC inspector review contained no purchasing or receiving inspection records concerning fuses, the inspectors reque ince sted examples of such information.
The licensee provided records for two fuse procurements, both through
- middlemen from Exide Electronics, an equipment manufacturer, in 1989; and from AMFAC Elect ic, a local distributor, in 1988.
The Material Disposition and Inspection Report for the Exide procurement was dated J
1989.
It specifies quantity, Material Code number (HNP-2 part une number),
vendor part number and code, current and voltage rating.
ID and marking, physical damage, and clean are marked satisfactory, dimension and weld prep.
are marked not applicable.
Th
im of understanding of the fuse manufacturer's processes is not e c a'
no sup ported by audit reports provided to the NRC inspectors.
There wa evidence of any audit of Bussmann, nor of knowledge that Bussmann c laims t
have a nuclear grade distributor.
Information concerning Bussmann's
quality assurance was found only in the form of informal telephon e memorandums written by licensee personnel.
Even though the Bussmann telephone memorandums state that length and resistance are measured, no evidence was seen that the licensee considered such information as critical characteristics.
Procurements appeared to be routinely accomplished through middlemen.
The only audit of Gould shown to the NRC inspectors was partial, since it did not address areas such as design and procurement document control; however, it did warn of a Mexican assembly plant with no known documented audits, and cautioned that if,any certification was desired, fuses should be ordered from a specific facility.
Gould later provided a sales policy that again offered certifications apparently not sought by the licensee.
Again, procurements appeared to be routinely accomplished through middle men.
The inspectors further noted that the June 27, 1989, telephone memoran morandums with Gould and Bussmann both stated the manufacturer
"no longer manufactures" nuclear grade or class 1E fuses.
This concern not only reinforces the question as to whether the fuses procured are the desired types, but also weakens the licensee argument that plant experience contributes significantly to dedication.
If traceability through middlemen is not accomplished, if characteristics such as engt l
h
and resistance are not monitored, if multiple manufacturing facilities exist, and if the manufacturer does not maintain material traceability and defect documentation procedures, then, experience with fuses built under programs no longer used is of questionable value in dedicating fuses of recent or even unknown date of manufacture.
The only "audit of UL activities" shown to the NRC inspectors reinforces the conclusion that UL listing is not sufficient for commercial grade dedications,.
For example, the report states that UL "does not actual,ly pull a listing mark unless a manufacturer shows continual poor performance through trending, has difficulties in implementing satisfactory corrective action, or is openly hostile towards U.L.
followup inspectors."
UL has also advised the NRC that the quarterly sample is much too small to derive any statistical inference with regard to product quality.
In addition, since the licensee stated that not all fuses are UL listed, in such cases,.
UL listing obviously provides no support for dedication.
The inspectors concluded that the licensee's dedication of commerical
'rade fuses was not acceptable because it did not provide reasonable assurance that the desired fuse,-with the desired characteristics was obtained.
There doesn't appear to be an immediate operability concern regarding fuse failure for the following reasons:
(a) loss of equipment operability in one division would not affect the ability of the redundant division equipment's ability to perform the required safety function; (b) the fuses are easily replaced in a minimal amount of time; and (c)
the licensee trending program has not identified multiple fuse failures.
Item No. 4:
Pressure Switch Installed)
.
The licensee's July 20, 1989, submittal stated that the Square D Company pressure switch was procured commercial grade because the licensee
"understood" the manufacturer no longer offered them as Quality Class I, although the licensee later learned that the switches were available as Class I.
A Stoneway Electric invoice showed that three switches were shipped from Square D in Asheville, North Carolina, on September 4, 1987.
Since three switches were receipt inspected by the licensee 12 days later',.reasonable traceabi lity through the middleman to the manufacturer appeared to exist in this case.
However, other questions applicable to procurements through middlemen remain unanswered, such as storage conditions, packaging, shipping, defect notification, and possibility of interchanging with items from distributor's stock, and the like.
The
~
inspectors noted that this procurement is a clear example of procurement through a middleman (Stoneway Electric) with the associated loss of procurement control.
The licensee's July 20, 1989 submittal stated that "the manufacturer's Quality Assurance department stated that these switches were made under the same QA program even when not offered as Quality Class I."
The file contained a July -19, 1989 letter to the licensee from Square D's manager of quality assurance, stating that all such pressure switches on the purchas'e order were "manufactured, inspected and accepted as conforming to all applicable Engineering Specifications."
When the NRC inspector asked for clarification of this statement, the licensee provided a
telephone memo written by the licensee and dated the day following the
/
'I request (September 14, 1989): It stated that Square D's gA manager said the switch did not come from a nuclear batch; "the same tests and inspections are done, but no records are kept for non-gCI batches."
Thus no documentation was found to show that the switch was manufactured under a guality Class I program.
The licensee's July 20, 1989 submittal listed six critical characteristics and stated that four of them were verified as part of standard receipt inspection:
range, contact rating, part no.,
and differential.
The receiving inspection report dated September 16, 1987 stated only "ITEMS I 8 2 ACCEPTED" and a dashed line is typed through twelve columns with headings ranging from "ID and Marking" to "Weld Prep."
and "Lube/Oils".
The licensee explained that the dashed line signified that all twelve characteristics were satisfactory, and that identification information provided in the purchase order would be covered in the inspection.
Contrary to the July 20 letter, the inspector noted that contact rating was not addressed in the receiving inspection documentation.
The licensee's July 20, 1989 submittal also stated that the manufacturer stated that no significant design changes occurred which would affect the mechanical integrity of the switch.
The inspector's request for'ocumentation of this statement was addressed in the September 14, 1989 telephone memo cited above, with Square D's gA manager, as follows:
"He did confirm that no design changes have taken place that decrease the pressure integrity of the switch.
He 'was also able to say that the only material change in approx.
5 years has been the plastic used in the terminal blocks.
He was unable to address all design changes made to the switch in the last 20 years because he did not have time.
However he did state that all design changes are analyzed/approved by engineering before they are implemented."
The licensee's retrospective dedication process was heavily dependent on verbal discussion with Square D (see quotes above).
For example, seismic integrity was identified in the July 20, 1989. as a critical characteristic, stated to be "assured-by the switch being a like for like replacement".
This assurance by the licensee was based on their claim of no significant design changes that invalidated the like-for-like integrity of the'eplacement parts.
This assurance by the licensee was based on the cursory discussion noted in the paragraph above where assurances in generality were given by the vendor.
The inspector concluded that the September 14, 1989 telephone memo between the vendor and licensee does not fully support the claim of component acceptability by the licensee in the July 20, 1989 submittal to the NRC, and since no prior supporting documentation was provided, the acceptability of this component is still in question.
Identification and verification of critical characteristics was incomplete.
For example, Rev. I of Evaluation 198 stated that materials need not be verified because there is a factor of two margin in the pressure rating, and performance as a pressure sensing instrument was not addressed except by reference to checks, calibrations, and tests at the time of installation.
These areas should be addressed as part of the
dedication process to verify safety related functional performance.
critical characteristics.
Summarizing, the licensee attempted to show retrospectively that the pressure switch was adequately dedicated, largely by means of certifications that were qualitative'in nature and did not adequately tie the switch to an Appendix B program.
Without adequate certifications, the other elements of the de'dication process such as identification and
.verification of critical characteristics are also inadequate.
Although the documentation reviewed by the inspectors, doesn't support a proper dedication process, there is reasonable evidence which indicates that the pressure switch was built to an Appendix B gA program.
Ther'efore, there doesn't appear to be an operability concern.
Item No. 5:
Metal 0-Rin s
( Installed These metallic 0-rings are fabricated from ANS 5582 Seamless Inconel X-750 tubing supplied by Superior Tube Company.
The tubing is formed into an O-ring, welded, smoothed to remove any welding irregularities
,
and silver plated per AMS 2410 at 1500'F.
These operations, performed by American Seal and Engineering Company, were not audited by the licensee.
The 0-ring material and the silver plate. are not considered to be critical characteristics'y the licensee, only 0-ring diameter and height (tube diameter).
The licensee stated in their response to Region V on July 20, 1989, that these 0-rings are specifically exempted as pressure boundary parts by ASME Code.
Also, that these 0-ring seals constitute a part of the containment pressure boundary between ECCS system relief valves and the containment suppression pool.
Subsection NB-2121(b) of ASME Section III,
,"Permitted Material Specifications,"
provides exemptions from Code requirements for items not associated with the pressure -retaining boundary.
It wasn't made clear to the inspectors how the 0-rings in question would qualify to be exempt from this section of the Code.
Regardless of any ASME exemptions these O-rings, or any other parts with safety functions, are not excluded from 10 CFR Part 50, Appendix B, gA requirements (NRC Information Notice No. 88-95).
A HUB Inc. audit report of Superior Tube was included in the documentation reviewed.
The audit was performed on February 10, 1989 for evaluation per ASME Section III NCA 3800, ANSI N45.2 and 10 CFR,50, Appendix B.
Although this was a satisfactory audit of Superior Tube no credit is claimed by the licensee towards acceptability of the O-rings.
Besides, the 0-rings were installed in 1988 with a Superior Tube CMTR dated June 2, 1977 via a packing slip of October 5, 1987.
Based on the information provided to the inspectors, no new evidence was provided to show that the critical characteristics were verified, or to
.support the licensee conclusion that the 0-rings are acceptable as installed.
The licensee's evaluation of the impact of failure of the 0-ring-on plant safety gave seal leakage or fai lure as'he only plausible failure mode, with insignificant effects on operability due to the small size of the lea Item No. 6:
EMD Diesel En ine Parts (In Stock Various spare parts for the emergency diesel generators were procured commercial grade -from General Motors Electro-Motive Division (END)
without being properly dedicated.
In their description of critical characteristics the licensee did not include material composition or properties, such as, chemical, tensile, heat treatment or impact properties.
Two audit reports of END were provided in the documentation package reviewed by the inspectors.
The
'first was a Wisconsin Electric audit performed by Gasser Associates.
This audit of EMD, performed on July 22, 1986, did not verify procurement document control or control of purchased material, equipment and services because General Motors considers that to be proprietary information.
Therefore the critical characteristics noted above could not be verified at EMD.
The second audit of EMD encountered the same situation.
This audit, performed by TVA on January 20-21, 1987, revealed that General Motors considers it to be TVA's responsibility to dedicate commercial grade replacement parts.
This issue was not addressed by the licensee.
END recently. reassigned their Authorized Distributorship for Nuclear Applications to Morrison-Knudsen (N-K).
The licensee audited M-K on August 15-17, 1989, to put N-K on the ESL for a source of third party dedication for END replacement parts.
The-audit report was still in progress during the NRC inspection; therefore no draft copy or other information on the audit results were made available to the inspectors.
The document'ation reviewed failed to substantiate the licensee conclusion that the END diesel parts were properly dedicated.
Accordingly, the inspectors consider these parts to be of indeterminate quality and should not be installed until properly dedicated.
Item No. 7:
HPCS-P-I Pum Shaft ( In Stock)
'uring the SSOMI, the pump shaft was identified as having been procured from a vendor not listed on the ESL.
Additional information provided to the inspectors revealed that the wrong vendor was identified and that
,
Ingersoll-Rand, who is on the ESL, supplied the pump shaft.
According to the licensee response of August 15, 1989, at the time of procurement,,
engineering wrongly determined the pump shaft not to be part of the pum'p pressure boundary.
Therefore, the part was procured as commercial grade from a vendor qualified to supply safety related parts, but was not audited to determine if the Ingersoll-Rand QA Program also covered commercial grade parts (in this instance the pump shaft).
During a telecon to Ingersoll-Rand on June 27, 1989, the licensee was informed that disregarding Quality Class (QC) commercial grade or QC-I requirements there is no possible way the subject shaft could have been manufactured other than to the original drawing and specifications.
However, there was no official documentation issued by Ingersoll-R'and to support this telecon.
Until this documentation is received, which will serve as a certification attesting to the quality of the item, this pump shaft is considered to have been inadequately dedicated and unacceptable for us Item No. 8:
GE Protective Rela s (In Stock Various types of GE relays were purchased commercial grade through North Coast Electric in 1988 on purchase orders 094920 and 094921.
They are intended for general plant use in safety-related applications.
Samples were selected from the delivered equipment and subjected to seismic type qualification testing by the licensee.
The test program included extensive performance measurements according to detailed type-specific procedures.
Brief review of the seismic test program indicated that it was satisfactory for dedication except for the following concerns.
The relays were ordered through a middleman.
The inspector found no evidence of traceabi lity to specific GE manufacturing lots or time frames, or of a basis other than random selection of test samples.
As a result, it is difficult to relate the test results,to any relays other than those tested.
This traceabi lity concern is exacerbated because the inspector found no evidence of audits of the manufacturing facility.
In fact, the file contained an internal licensee letter dated July 13, 1989 requesting an audit of GE's relay division, but when the inspector requested the status of that audit the licensee advised that it was cancelled.
Detailed performance-related critical characteristics were not spelled out in the dedication evaluation, b'ut were covered by reference to plant, procedures, intended to be performed at the time of installation.
The inspectors noted that the licensee's procedures had not been revised to ensure that all specified critical characteristics are in fact addressed when each individual component or part is installed.
Furthermore, procedures do not ensure that subsequent revisions to the plant procedures continue to address all critical characteristics, or that completed installation test data are reviewed by dedication personnel.
The inspectors also noted that it would further be necessary to maintain items with incomplete dedication in a special restricted-use category unti 1 dedication is completed.
The simple assumption that a referenced plant procedure will always verify the functional critical characteristics at the time of installation is not acceptable.
Summarizing, the licensee's seismic test program provides important input for the dedication process, but additional efforts are necessary to complete the dedication of GE relays.
Item No. 9:
Chiller Shaft In Stock The chiller shaft was procured from York International on Narch 17, 1989.
Two audits were performed of York International by the licensee, one at the York, Penn. facility on August 1-2, 1989 and the other audit on August 10, 1989, at the Baltimore Parts and Distribution Center in Baltimore, Naryland.
The audits were performed in accordance with an Interoffice Nemorandum ( ION) from the Plant Technical supervisor to the.
gA Procurement Nanager, dated June 20, 1989.
This ION requested that the audits be performed as defined on the audit criteria sheets.
Three important criteria were not addressed during the audits as documented in gA Evaluation Report Nos. 89-26 and 89-27; these are:
'
a.
Under Design Control, "j. Does the vendor identify critical characteristics to be controlled?"
b.
Under Procurement Control, "i. Are receipt inspections perfo'rmed to assure critical characteristics and quality a'e acceptable?"
and c.
Under Test and Inspection Controls,
"b. Are any tests and inspections conducted to verify critical characteristics?"
These 3 criteria were not audited or addressed in the commercial grade audits of York International, yet, the 1'icensee concluded that they maintain sufficient control of materials.
The inspectors concluded that the shaft was inadequately dedicated and that these additional audits did not address the critical characteristics necessary to support a proper dedication process therefore the part is still considered to be-of indeterminate quality.
Item No. 10:
Aschroft Pressure Gau e- (In Stock These bourdon tube type pressure gauges were purchased commercial grade through Paramount Supply in 1986 on purchase order 083283.
They provide local indication of emergency diesel generator oil pressure; the only safety-related function is to maintain pressure integrity to 40 psig.
The licensee relied on a Portland General Electric survey report of Ashcroft, dated February 1989, for assurance that Ashcroft's gA controls permit reliance on the part number for verification af materials and configuration.
The NRC inspector briefly reviewed the survey report, which appeared to cover most of the areas significant to commercial grade listing of the manufacturer.
However, the licensee addressed neither the three year period by which. the procurement preceded the survey, nor the impact of the licensee's procurement through a middle man.
Although the Receiving Inspection Report was as, vague as that described above for the fuses, the body of the purchase order did specify certain configuratio'nal aspects cited in the licensee's August 15, 1989 submittal. 'ne must assume that the entry "ITEN 1 ACCEPTED" and a line typed through columns headed
"ID and Yiar king" and "Dimension" cover such characteristics as flush mounting and 4$ inch diameter dial face.
Part number and certain other characteristics were also verified.
The 'licensee's evaluation states that one gauge is already installed, and operating experience with that gauge adds further assurance concerning the others.
The evaluation also states that each gauge will be calibration/bench tested to 60 psig, or 1504 of requi~ed, prior to installation.
4.
Conclusions The licensee appears=to be taking a strong position. that their commercial grade procurement program currently is, and always has been, in full compliance with NRC requirements.
The NRC does not agree and is concerned that there have been several meetings and exchanges of correspondence with the licensee which indicate a lack of licensee
recognition and understanding of NRC concerns involving commercial grade procurement deficiencies at WNP-2.
Specifically:
a.
The NRC has applied limited resources to the review of specific instances of commercial grade procurement and has identified several problem areas.
Although the specific examples do not appear to involve significant plant safety concerns, they all involve root causes which imply a generic deficiency in the controls which have been exercised by the licensee over commercial grade procurements.
b.
It is not enough to only upgrade efforts in this area for future procurement activities.
It is important to realize that past practices have not been adequate and that further actions are needed to ensure that other examples of greater safety significance do not remain undetected.
'c.
The NRC is concerned with the apparent reluctance of the licensee to aggressively pursue the areas of NRC concern.
For example:
( 1)
In several instances, recent WPPSS responses to NRC concerns have stated conclusions which, upon independent review by the NRC, are not supported by'he referenced documents.
(e.g.,
as noted in items 3, 4, 6 and 9 above.)
(2)
In most instances, the WPPSS responses to NRC concerns have been superficial, dealing in generalities rather than focusing on quantitative evidence (e.g.
numerous instances of telecons used as the basis for WPPSS determination of the acceptability of commercially supplied material, as noted in items 3, 4 and
above).
(3)
In several instances,
'the WPPSS responses have lacked rigor and continuity in their thought processes (e.g., fai ling to address
"middle man" suppliers, as noted in items I, 3, 4 and 8 above).
(4)
In several instances, the responses continue to fail to address proper definition of component critical characteristics or proper verification of these critical characteristics.
(e.g.
as noted in items 3, 5, 6 and 9 above).
(5)
In some instances, the licensee continues to purchase important safety related parts as commercial grade, without adequate site dedication, although the parts are available with supplier dedication (e.g. fuses).
5.
~E The inspectors met with licensee representatives denoted in paragraph l.
on September 14, 1989.
The scope and findings of the inspection were discussed as described in this report.