IR 05000482/1988015

Insp Rept 50-482/88-15 on 880328-0401.Violations Noted.Major Areas inspected:10CFR21 & Procurement Program

ML20154H392
Person / Time
Site:	Wolf Creek
Issue date:	05/06/1988
From:	Barnes I, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154H378	List: IR 05000482/1988015 ML20154H374 ML20154H391
References
50-482-88-15, NUDOCS 8805250324
Download: ML20154H392 (6)

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APPENDIX B-U.S. NUCLEAR REGULAT0RY COMMISSION

REGION IV

- NRC Inspection Report: 50-482/88-15 Operating License: .NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

P.O. Box 411 Burlington, Kansas- 66839 Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS, Burlington, Kansas Inspection Conducted: March 28 through April 1, 1988

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Inspector: n h 6 W.7 .' McNeill', Reactor Engineer, Materials Datel '

and Quality Programs Section,. Division of Reactor Safety

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Approved: 3%e I. Barnes, Chief, Materials and Quality r/r, /d'[

Tate Programs Section, Division of Reactor Safety Inspection Summary

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Inspection Conducted March 28 through April 1, 1988 (Report 50-482/88-15)

Areas Inspected: Routine-and reactive, unannounced inspection of 10 CFR Part 21 and the procurement program.

1 Results: Within the two areas inspected, one violation was identified -(three failures to identify requirements in purchase requisitions, paragraph 3).

8805250324 880516 PDR ADOCK 05000482 g DCD

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DETAILS

! Persons Contacted WCNOC j

• G. D. Boyer, Plant Manager M. D. Charlton, Supervisor, Supplier Quality and Material Support

• L. E. Cook, Supervisor, Supplier Surveillance T. B. Dougan, Quality Assurance (QA) S)ecialist

• A. A. Freitag, Manager, Nuclear Plant Engineering

• R. E. Gimple, Supervisor, Materials Quality

• R. M. Grant, Vice President, Quality R. A. Hebeler, Engineering Specialist

• C. J. Hoch, QA Technician K. E. Hollon, Supervisor, Procurement Evaluation

• W. M. Lindsay, Manager, Quality Evaluation

• G. J. Pendergrass, Licensing Engineer K. R. Petersen, Supervisor, Licensing R. J. Potter, Manager, Material and Supplier Quality

• F. T. Rhodes, Vice President, Nuclear Operations

• G. Williams, Manager, Plant Support

• Denotes personnel attending exit meetin The NRC inspector also contacted other personnel including administrative and clerical personne . 10 CFR Part 21 (36100)

i The objective of this inspection was to determine whether the licensee has l established and was implementing procedures and controls to ensure the <

reporting of defects and noncompliances. In this regard, the NRC j inspector reviewed the Updated Safety Analysis Report (USAR) and WCN0C l Administrative Procedures01-033, "Instructions Describing Peportability, i Review, and Documentation of Licensee Event Reports (LERs), t.nd Defect i Deficiencies," Revision 16, dated October 27, 1987; and 01-085, "10 CFR Posting Requirements," Revision 1, dated December 31, 198 The NRC inspector found that the administrative procedures in place were being implemented. The posting requirements of 10 CFR Part 21 were satisfied at the security access point. A review of recent purchase orders (518200, 521701, 520403, 521603, 521606, 523707, 521208, 520009, 523312,523212,519313) found that the requirements of Part 21 were passed onto suppliers and their subsuppliers. Three recent problems were

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reviewed in detai Only one of these ha,. result' d in a Part 21 report to the NRC which wes made during the course of this inspectio The other two are still in the evaluation proces No violations or deviations were identified in this area of the inspection, j 3. RocurementProgram (38701)

The objective of this inspection was to ascertain whether the licensee was implementing a QA program to control procurement activities that was in conformance with regulatory requirements, licensee commitments, and industry guides and standards. This inspection was performed as a result of the identification by WCNOC that pressure boundary parts which were not 1 in compliance with applicable ASME Code requirements had been installed in two valves, Program Review l l

The NRC inspector reviewed the USAR and the following procedures: l

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QAP 4.1, "Processing of Procurement and Related Documents,"

Revision 1, dated December 16, 1987, with Procedure Change Notice (PCN) No. *

QCP 7.1, "Receipt Inspection," Revision 5, dated March 30, 1987, with PCN Nos. 1- l KP-2140, "Material and Services Procurement," Revision 1, dated March 14, 1988, with PCN Nos. 1- QAP W4.1, "QE Processing of Procurements Documents," Revision 0, dated June 22, 198 The NRC inspector found that controls were established in procedures to assure that documentation, quality, and technical requirements were identified in purchase orders. Review of the procurement process showed that a specific need is identified in a material requisition which in turn becomes a purchase requisition and that later in turn results in a purchase order. The documentation, quality, and technical requirements are identified in purchase requisitMns oy procurement evaluation specialists. The QA review is performed at the purchase requisition stage. In the case of Westinghouse he. lear Services Integration Division (WNSID) renewal spare parts orde: s, the purchase orders reference a WNSID documen OPR 405-5, "Renewal Parts Procurement and Supply System." The WNSID purchase order and the referenced procurement documents are used to supplement the WCNOC procurement documents. For other procurement, WCNOC performs the qualification of suppliers and the establishment of an approved supplier list called a Supplier Information Lis This activity is performed by WCNOC personnel located in the Wichita office . . _ . - . , - - . . - -

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l b. Review of Valve Procurement Documents l I

The procurement activities associated with the valves identified in l WCNOC letter ET 88-0043 dated March 22, 1988, were reviewed in l detai This letter was a request for relief from ASME Code ,

requirements for two valves that had been installed and subsequently l found not to have proper ASME Code documentation. The valves in i question were a pressurizer spray valve and a reactor coolant pump  !

seal water injection throttle valve. The material requisitions, '

purchase requisitions, purchase orders, and associated procurement documents were reviewed by the NRC inspector. The receiving inspection reports, document deficiency notices, nonconformance reports, and supplier documentation were also reviewed by the NRC inspector. In the case of the pressurizer spray valves, they were procured under the WNSID renewal parts program indirectly from Fisher Controls. The reactor pump seal water injection throttle valves wer .

procured directly from Yarway Corporatio (1) Pressurizer Spray Valves l In regard to the WNSID-Fisher order, the WCNOC purchase requisition failed to identify that ASME Code pressure boundary .

parts were being ordered for which ASME Code' Data Reports were' l required. This was identified as a violation (482/8815-01).

The procedure in question (QAP 4.1) does.have some conflicting instructions. Paragraph 7.1.1 references a checklist to be used, and paragraph 7.1.3.C requires the Supplier Information List to be used in part. However, the checklist requires all of the Supplier Information List to be used. The Supplier Information List applicable to WNSID also required that ASME Code parts be identified in purchase orders. It should be noted that the parts being ordered were somewhat mislabeled in that the parts were described as.a packing' box assembly, a non-pressure boundary part; however, they were indeed the valve bonnet, a pressure boundary part. In addition to the WCNOC failure to identify the parts as pressure boundary, WNSID also failed in their review of the purchase order to identify that the parts were pressure boundary part The parts were classified as code D in lieu of the applicable code A for pressure boundary parts. Subsequently, WNSID subcontracted the order to a non-ASME Fisher Controls shop. Fisher Controls also failed to recognize that they were to supply the same as original equipment as was identified in the purchase order from WNSID by reference to the original Westinghouse E-Specification and purchase orde (2) Reactor Pump Seal Water Injection Throttle Valves In regard to the Yarway order, similar errors occurre This order likewise failed to identify that TSME Code Data Reports were required. This was identified as a second example of a

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violation (482/8815-01). In a purchase order attachment. %

requirement for ASME Code Data Reports was marked "NA." The parts in question were identified as for a code assembly; however, because the design specified for a welded stem disk assembly the parts then required an ASME Code Data Repor Yarway also failed to respond to the requirements to supply the same as original equipment. This was identified by reference to I the Bechtel specification and purchase orde !

c. Additional Review of WNSID Procurement i The procurement of renewal spare parts under the WNSID program was reviewed in further depth by the NRC inspector. A sample of 12 recent purchase orders were reviewe The equipment ordered i varied in system applications from reactivity to electrical system l Most of the orders were for safety-related parts; however, some were for important-to-safety parts. In this review, it was noted that

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Westinghouse E-Specifications were not referenced in purchase orders I or requisitions by their revision status. This was identified as another example of a violation (482/8815-01). The licensee l considered that a purchase order which contained the Westinghouse I Standard Plant Identification Number or SPIN :nd a part number was sufficient information for procurement. It should be noted that Westinghouse E-Specifications do identify more than one project on occasion. Exact information in orders it would seem, based on the above referenced problems, is necessary. The supplier trend information for WNSID was reviewed and it was found by the NRC inspector that about 2400 safety-related orders are issued on an i annual basis. WNSID orders are 75-100 annually, however, WNSID is responsible for 130-160 document deficiency reports, nonconformance I reparts, or corrective action work request I l

d. Corrective Actions In regard to the problems identified with the failure to have ASME Code Data Reports which have been identified recently, it is planned to document these problems on Programatic Deficiency Reports. The specific nonconformances are presently documented on Nonconformance l Reports M-1116 and M-1117 and corrective action work requests 1261-88 and 1285-88. The licensee has planned to move the ASME Section XI

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review of replacement activities from after installation to prior to installation; this is so that the absence of ASME Code Data Reports can be identified earlier. The NRC inspactor could not evaluate the generic corrective action in that it was still in the planning stages and was not documented. This was identified as an unresolved item (482/8815-02). It would seem that some steps should be taken such as review of other Yarway orders, other stem disk assembly orders, other orders reviewed by the same personnel or other orders in genera Some WNSID orders have been reviewed and more are planned to assure

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_ that misclassification or mishandling has not occurred on other such

' orders. All of the above, it-would seem, are necessary to assure that there are no materials in storage which fail to have applicable ASME Code Data Reports or other required documentatio . 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 item was discussed in this report:

Paragraph Item Subject 3 482/8815-02 Generic Corrective Action 5. EjtMeeting

The NRC inspector conducted an exit meeting on April 1, 1988, with the licensee personnel denoted in paragraph.l. The NRC senior resident -

inspector also attended. At this meeting, the scope and findings of the inspection were summarize i

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