ML20006D040

Responds to NRC 900103 Ltr Re Violations Noted in Insp Rept 50-285/89-46.Corrective Actions:All commercial-grade Matl Purchases for Critical Quality Element Applications,Between 860101-880428,will Be Reviewed Re Compliance W/Qa Plan

ML20006D040
Person / Time
Site:	Fort Calhoun
Issue date:	02/02/1990
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-90-0092, LIC-90-92, NUDOCS 9002120034
Download: ML20006D040 (5)

Text

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1 Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536-4000 .)

February 2, 1990 ,

LIC-90-0092 i

. 1 U. S. Nuclear Regulatory Commission Attn: Document Control Desk  !

Mail Station P1-137 Washington, DC 20555 'l

References:

1. Docket No. 50 285 I

2. Letter from NRC (S. J. Collins) to OPPD (K. J. Morris) dated -;

January 3, 1990 j Gentlemen.  ;

SUBJECT:

Response to Notice of Violation (NRC Inspection Report 50-285/89-46) .

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i Omaha Public Power District (OPPD) received the subject inspection report l (Reference 2) which identified one violation regarding commercial grade  !

dedications. Attached please find OPPD's response to this item in accordance with 10 CFR Part 2.201..

The Reference 2 cover letter identified an NRC concern regarding the potential l

for the installation of materials that may have an adverse impact on system  ;

operability requirements. A request was made for a description of actions l and/or measures assuring that essential systems have not been adversely p affected by replacement of Critical Quality Elements with commercial grade items. The necessary actions to assure that essential systems have not been  ;

adversely affected are addressed in the attachment to this letter.

If you should have any questions, please contact me, f Sincerely, L. - g n e-: .A JL%

.W. G. Gates I go Division Manager ,

Nuclear Operations of ,

i :Ed WGG/pje oo

' @@ Attachment om- c: LeBoeuf, Lamb, Leiby & MacRae

@@o R. D. Martin, NRC Regional Administrator, Region IV A'. Bournia, NRC Project Manager '

P. H. Harrell,>NRC Senior Resident Inspector as = tmo,oumeoggonoo,;om,o y

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION l During an inspection conducted on November 27 through December 1, 1989, a i violation of NRC requirements was identified. The violation involved the failure to dedicate commercial grade items purchased for use in safety related applications. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the i violation is listed below:  ;

Criterion III of Appendix B to 10 CFR Part 50 requires that measures be ,

established for the selection and review for suitability of application of i materials, parts, and equipment that are essential to the safety-related .

functions of the structures, systems, and components.

This requirement has been implemented by OPPD through Procedures GEG-29 and GEI-32. Both of these procedures require the evaluation of commercial grade iteins for suitability of use in safety-related applications.

Contrary to the above, the following conditions were identified:

a. 09cumented measures were not established prior to April 1988, with respect to evaluation of commercial grade items for safety-related applications. Five examples were noted with respect to procurements made before formal establishment of program requirements, where proper evaluations had not been made of suitability of commercial grade items for use in safety-related systems,

b. Two examples were noted with respect to procurements made after .

program establishment, where commercial grade items were not traceable '

to original equipment seismic qualifications.

This is a Severity Level IV violation. (Supplement II)(285/8946-01)

OPPD Response:

1) The Reason for the Violation, if Admitted As noted below OPPD admits Item a, occurred as stated, and denies Item b.

a. This item is admitted.

A review conducted by OPPD following the inspection determined that documented measures for acceptance of Commercial Grade Items for l Critical Quality Element (CQE) applications were established prior to April 1988. Requirements for engineering evaluation of commercially available "off-the-shelf" items to be used in CQE applications existed in OPPD's Quality Assurance (QA) Plan, Section 4.0, dated September l 1984 Guidance was provided to the QA organization via departmental procedure QADP-12, " Material Acceptance and Receipt Inspection," dated March 1984.

.f : . . j Although the methods employed prior to April 1988 were not as  !

comprehensive as the program in place today, the methods are considered i to have been adequate to assure the quality of materials and the safety i of the public.  :

OPPD ccknowlehes however, that the examples identified in the  !

violation illustrate that the uss of commercial grade items prior to establishment of the current program warrants review to assure that essential systems have not been adversely affected. ,

b. OPPD denies this example of the violation.

Traceability of Yokogawa meters purchased under P0s SO46624 and S042766 .

to original equipment qualification was based on a part numbering convention for GE/Yokogawa equipment. The Yokogawa meters were identified by part number and supporting documentation as having been manufactured to the same design requirements as the corresponding GE meters being replaced. A Certificate of Conformance was provided to docunent that the materials supplied were the materials ordered. This method was in accordance with dedication packages based upon OPPD's procedure for Commercial Grade Item Dedication, GEG-29, that was in effect from April- 1988 through July 1989. In addition, the dedication packages required verification of dimensions and a calibration /

functional check in accordance with prescribed acceptable procedures.

The results of the above dimensional checks showed that the GE/Yokogawa meters had the same dimensions as the original GE meters. The results -

of the calibration / functional check showed the function of the GE/Yokogawa meters to be consistent with that of the original GE meters. OPPD considers the available documentation adequate to provide reasonable assurance that no changes had occurred since the original meters had been manufactured by GE.

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2) Corrective Stens That Have Been Taken and the Results Achieved a Part a of the Notice of Violation cited a total of five (5) examples of PO packages with potential problems. These examples are described in greater detail in Inspection Report 89-46, Section 4.c. on Commercial Grade Item Procurement Prior to Program Implementation. -

p Three of the five examples have been researched and where appropriate, corrective actions have been taken. The other two examples are

! addressed in Section 3 of this response. Results of the research are i l summarized below.

Item 4.c.(1) P0 C097855, see Section 3 " Corrective Steps That Will l

Be Taken To Avoid further Violations." t l Item 4.c.(2) P0 C097976, dated June 4, 1987, to BOSCO Fastening Service of Omaha, Nebraska for 500 each, 1-inch by 3-inch bolts, hex head, SAE Grade 5. ,

It has been determined that 278 of the 500 bolts have been issued i from the FCS warehouse, of which 10 were installed in 5 CQE conduit supports under modification MR-FC-86-ll7 and 268 were l

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installed in non-CQE applications. 222 bolts remained in the  :

warehouse which have been " HOLD" tagged to restrict their use. A Commercial Grade Dedication package has been prepared in  :

accordance with the current guidance of PED-GEI-32.- The package '

required metallurgical testing of a representative sample of the bol ts. This testing has been conducted. A sample of 25 bolts was i shipped for testing to Taussig Associates, Inc. of Skokie, ,

Illinois. Taussig appears on the OPPD Routine Supplier's List. ~

The testing performed was proof load, wedge tensile, surface hardness and chemical composition in accordance with SAE J429, ,

August 1983, paragraphs 5.3, 5.5, 5.2, and 3.1 and Table 2, respectively. The results of this testing (now on file with OPPD) '.

show that the sample of 25 bolts conform to the proof load, wedge tensile, surface hardness and chemical composition requirements of' SAE J429, Grade 5 dated August 1983, i Based upon the test results from Taussig, dimensional verifica-tions and identification marking verifications required by

• Commercial Dedication MER 89-1768, the bolts purchased from BOSCO Fastener Service of Omaha, Nebraska under P0 C097976 have been '

confirmed as acceptable for use in the intended application.

Item 4.c.(3) P0 S019715, dated May 11, 1987 to General Electric +

Supply Company (GESCO) of Omaha, Nebraska for five (5) each .

auxiliary switches, GE Type SBN 10AX006G4 for 4160 volt switchgear.

Research revealed that one (1) switch was installed on a 4160 volt '

breaker. The breaker was removed as a conservative measure and replaced with a spare breaker upon which a CQE auxiliary switch is ,

installed. The remaining four (4) switches were not installed based upon a Maintenance Order and Modification search.

Item 4.c.(419_SD12221 dated May 14, 1987, to GESCO, Omaha, Nebraska for two (2) each switches, GE Type 165BIEB4C83SPR2P.

Research was conducted to account for the two (2) switches. The '

research revealed one (1) of the switches to be installed on a CQE 480 volt breaker. The switch has been removed from the breaker as a conservative measure and replaced with a CQE switch from a spare 480 volt breaker. The remaining non-CQE switch was not installed based upon a Maintenance Order and Modification search.

Item 4.c.(5) p0 S012973, see Section 3 " Corrective Steps That Will Be Taken to Avoid Further Violations."

To date, 11 CGDs done after April 1988 have been reviewed with no discrepancies or deficiencies found.

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3) Corrective Steos That Will Be Taken to Avoid Further Violations To provide assurance that commercial grade materials for CQE l applications perchased before April 1988 (i.e., before implementation of the current' extensive program) are acceptable for continued use, all commercial grade purchases for CQE applications between January 1, 1986 ar.d April 28, 1988 will be reviewed for compliance with the requirements of QA Plan Section 4.0 and QADP-12 that were in place at that time. This review will include P0 #C097855, dated March 20, 1987, to Great Plains Industrial Supply Company (item 4 c.(1) of Reference 2) and PO #S012973 dated October 3, 1986 to Satin America Corporation

! (item 4.c.(5) of Reference 2). The review will be documented and any c problems found will be resolved on a case-by case basis. The review

and documentation will be complete by June 9, 1990. Prior to January r

1, 1986 commercial grade procurement for CQE applications were comparatively infrequent.

OPPD considers the above activities to be adequate to assure that materials which may have an adverse impact on operability requirements have not been installed, or have been replaced if previously installed.

4) Date When full Compliance Will Be Achieved In that the current CGD 3rogram closely follows the guidelines of EPRI NP 5652 " Guideline For tie Utilization of Commercial Grade Items in Nuclear Safety-Related Applications (NCIG-07)," and that the Procurement Engineering Group is fully staffed, OPPD is currently in full compliance.

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