IR 05000528/1989038
| ML17304B417 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/18/1989 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304B416 | List: |
| References | |
| 50-528-89-38, 50-529-89-38, 50-530-89-38, ABS528-89-38, NUDOCS 8909080153 | |
| Download: ML17304B417 (12) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report Nos. 50-528/89-38, 50-529/89-38, 50-530/89-38 Docket Nos. 50-528, 50-529, 50-530 License Nos.
NPF-41, NPF-51, NPF-74 Licensee:
Arizona Nuclear Power Project P. 0.
Box 52034 Phoenix, Arizona 85072-2034 Facility Name:
Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and
Inspection at:
Palo Verde Site, Wintersburg, Arizona Inspection Conducted:
June 19 through July 28, 1989 Inspector:
Approved by:
W. J.
Reactor Inspector uey, se; ng s neer'g ec n
~ i8 S't ate
>gne
~Summae:
W Ins ection on June 19, 1989 - Jul 28 1989 (Re ort Nos. 50-528/89-38,
-5 0-Areas Ins ected:
An unannounced inspection by a regional inspector of commercia grade procurement.
Inspection Procedure Nos.
30703 and 38703 were used as guidance for the inspection.
Resu1ts:
General Conclusions The licensee's procurement program is weak in the way commercial grade items are dedicated for safety-related use in that the critical characteristics of the items are not fully verified by testing or inspections.
Si nificant Safet Matters:
None Summar of Violations or Deviations:
None 0 en Items Summar
One unresolved item regarding dedication of commercial grade items or contended safety-related application DETAILS Persons Contacted The below listed technical supervisory personnel were among those contacted:
Arizona Nuclear Power Pro 'ect ANPP 2.
~R. Badsgard, Resident Engineering Supervisor O'. Ballard, Sr. Director QA/QC N. Dougherty, Supervisor Stores S. Grier, Lead Procurement Engineer
+R. Fullmer, Nanager, Quality Audits P,
D. Hackbert, Quality Audits Supervisor
'.
Henson, Electrical Systems Engineering Supervisor A. Howard, Supervisor of Contracts P4S. Karimi, Compliance Engineer 0 J. Kirby, Director, Nuclear Production Support J. Natteson, Quality Monitoring Supervisor P<L.
L'. Papworth, Director, Site Services S. Penick, Procurement Engineering Design Control
+R. Prabhakar, Nanager, Quality Engineering 8 L. Spiers, Inventory Control Supervisor 0 T. Thompson, Resident Electrical Engineer D. Young, Senior Procurement Quality Engineer J. Zalitis, QC Inspector The inspector also talked with other licensee personnel during the course of the inspection.
Attended the Exit Meeting on June 23, 1989 Attended the Exit Meeting on July 28, 1989 Commercial Grade Procurement (38703 The methodology and procedure for determining the requirements and documentation needed to dedicate commercial grade items for safety-related use is established in licensee Instruction No. MS01.04.03 entitled "Item Procurement Specification ( IPS) Requirements",
Revision 0, dated October 4, 1988.
Section 2.11 of this instruction defines critical characteristics for parts as those properties or attributes that are
'essential to the safety function of the component in which the part is installed.
Typical critical characteristics which must be identifiable and measurable, according to Section 2. 11, are attributes such as dimensions, materials, electrical and temperature parameters, output tolerances, and fluid consistency.
Implementing references used in conjunction with this instruction for determination and dedication requirements are INS01.04.01 [(Material Engineering Evaluation (MEE)] and 71414.01.06
[(Equipment Change Evaluation (ECE)].
The NEE instruction was superseded on April 22, 1989, by procedure 12DP-OMC06.
NEE/ECE evaluations include completing Form D for commercial grade dedicatio Form D specifies the applicable critical characteristics and the verification methods.
These evaluations are prepared by the Responsible Engineer (RE) within the Procurement Engineering organization.
The inspector reviewed the engineering evaluations, as documented on Form D, to assess the adequacy of the evaluations.
From this review and subsequently related discussions with licensee personnel, it appears that the engineering evaluations were not technically adequate because, in some cases, the critical characteristics were missing to properly dedicate an item, or, as in most cases, the method of verification was insufficient to verify the critical characteristics.
During the inspection, the inspector identified the following examples of commercial grade procured items that appear to have been inadequately dedicated and installed in the plant:
'a
~
E ebolts - These eyebolts were used in safety-related bolting app ications for valves located in the Reactor Coolant (RC), and Chemical and Valve Control (CVCS) systems in Unit 2.
Although not yet installed, these eyebolts will.also be used for valves located in the SI system in Unit 1.
The last PO No. was 33603877, dated 5/16/89, issued to Borg-Warner Industrial Products; the engineering evaluation (ECE-RC-A033)
was performed on 12/9/87.
The material is ASTN A564, Grade 630, which is the standard specification for
"Hot-Rolled and Cold-Finished Age-Hardening Stainless and Heat-Resisting Steel Bars and Shapes."
This item was bought from a vendor.
on the Approved Vendors List (AVL), but the vendor was not audited to determine if the gA program covered commercial grade eyebolts.
Yiaterial/composition was specified on Form D as a
critical characteristic with the method of verification being by use of a magnet.
A magnet will not provide adequate verification of chemical composition.
Chemical composition (Fe, Cr, C, Ni) and physical properties (yield, tensile and impact strengths)
are missing from the list of critical characteristics.
,The eyebolts were installed on Work Order (WO) Nos.
325753, 325782, 326620 and 264816.
b.
Barksdale Pressure Switches - These were purchased from Cooper nergy ervices Group on No. F-186178 with dedication performed under ECE-RC-033 on I/16/87.
The pressure switches are used in the Emergency Diesel Generator starting system and alarms.
The safety-related function is to maintain system pressure boundary.
The switch has to remain functional in the event of a safe shutdown earthquake.
The engineering evaluation said that physical comparison of the Barksdale pressure switch with a qualified Barksdale pressure switch showed no detectable difference; and, therefore, concluded that the pressure switches are qualified for safety-related service based on this similarity and are dedicated for use as listed on Form D.
Based on this evaluation, the critical characteristics verification consisted of comparison with the vendor catalog and a picture from a qualification report.
The inspector concluded that the following action was necessary to properly dedicate these pressure switches (as stated in the Notes section on sheet 2 of Form D):
"For future dedication, the following have to be verified 1.
2.
3.
5.
Model No. (Switch No.)
Pressure Ratings Contact Ratings Mounting Details Physica1 and Electrical interface" These pressure switches were installed in Unit 1 by Work Order Nos.
301516 and 369717, and in Unit 3 by WO No. 36717.
Journal Bearin PO No. 60108557 and Throat Bushin PO No.
60109
- Bot of t ese items were pure ase rom Bing am-Willamette Company (B-W) on Purchase Orders which required B-W to have an approved gA program and imposed
CFR 21 (Part 21)
reporting responsibility.
B-W refused to accept the Part
requirement, because the items were not unique to the nuclear
, industry, and'upplied the two items as commercial grade with a Certificate.of Compliance (C of C).
Procurement Engineering initiated ECE-AF-A011 to evaluate the Part 21 responsibility, and MEE-0053 to evaluate whether the journal bearings can be procured as commercial grade/safety-related.
Both evaluations state that the two items perform a safety-related function to the safe operation of the Auxiliary Feedwater (AFW) pump (turbine driven).
NEE-00053 further states that the failure of the Journal Bearing would adversely affect AFW pump operation.
The evaluations also revealed that the items receive additional machining by B-W after receiving the items from their subsupplier.
The evaluation concluded that the items are acceptable without Part 21, with the licensee assuming the Part 21 reporting responsibility after dedication.
Dedication was based on receiving a
C of C; the ECE, and QC receipt inspection.
The inspector's review of these evaluations concludes that the critical characteristics were not adequately verified.
For example, the journal bearing was specified as a cast iron body per ASTN A48, Class 30, with a nickel-babbitt liner.
Verification of. the material was by magnetic test.
The magnetic testing for verification of material is considered unacceptable unless it can be supplemented by a licensee audit verifying that B-W has the necessary quality program to assure the critical characteristics necessary to dedicate these parts have been met.
This audit should address B-W controls over their vendors.
Although B-W is on the AVL the licensee audit did not address whether the B-W OA Program includes commercial grade items.
These items were installed by WO Nos.
304552 (Unit 1) and 208486 (Unit 3).
Control Valves -.The valves were supplied by Air Draulics on PO No.
Cip d
1 p lib'<<ig f h
diesel engine when the turning gear is engaged.
The critical characteristics required verification by use of, a magnetic test that the material/composition was Brass.
Also, Air-Draulics had not been audited by the'icensee.
These control valves were installed in the Unit 1 diesel engines on WO Nos.
356383 and 35660 Gear Reducers
- ECE-CH-A055 evaluated the a'cceptability of procuring charging pump gear reducers as commercial grade.
This evaluation allowed procurement of the Falk gear reducers as commercial grade rather than through Combustion Engineering who is on the AVL.
These gears were purchased on PO No. 33504702 from American Export Trading Co.,
who was not listed on the AVL, nor had any special audits been performed to determine their acceptability to supply these items.
Receipt inspection for verification of critical characteristics consisted of configuration and dimensional checks, magnetic verification that the material was steel, and nameplate data verification.
From the documentation reviewed by the inspector, the vendor who supplied the gears was 'not audited; nor was Falk, the manufacturer and supplier to American Export Trading Co, audited.
Based on the review it appears that these gears were not adequately dedicated for safety-related use.
The gear or gears were installed by WO No. 333624 in Unit 3.
The following are additional examples of commercial grade procured items that have been inadequately dedicated for safety-related use, and which were available for issue, but were not installed:
Terminal Boards -
GE EB-1 terminal boards were dedicated, on Cf-CC, <ary o>st
5 ton reactor room bridge crane and, since it is a load bearing'art of the crane, is considered to be safety-related.
The shaft assembly was supplied by Whiting Corporation, who was listed on the AVL; but, as noted in previous examples, it was not determined if the vendor's QA program covered commercial grade products.
The critical characteristics of
'
material/composition were verified by the ability to draw a magnet; no chemical or physical requirements were verified.
This item was authorized for installation in Unit 1 polar crane by.WO No. 258942, but the work was not done yet.
h.
Camshaft Hub Drive - This item was supplied by Cooper Energy Services Group for use on the Cooper-Bessemer camshaft on the emergency diesel engines.
As previously noted, this vendor had not been audited to determine if their commercial grade products are covered by their gA program.
Material/composition was verified by ability to draw a magnet, which does not provide verification of physical and chemical properties needed to dedicate the part.
The inspector will review additional licensee supplied information
.regarding procurement activities and the specific safety function of these replacement parts during a future inspection.,
This is an unresolved item (50-528/89-38-01, 50-529/89-38-01, 50-530/89-38-01).
3.
Unresolved Items 4.
An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable item, a deviation, or a violation.
An unresolved item is documented in paragraph 2.
~Ei The inspector conducted exit meetings on June 23 and July 28, 1989, with license representatives denoted in paragraph l.
During these meetings, the inspectors summarized. the scope of the inspection activities and reviewed the inspection findings as described in this report.
The licensee acknowledged the concerns identified in the repor \\I I
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