ML20012E054

Forwards Insp Rept 50-458/89-200 on 891023-27 & 1113-17. Deficiencies Noted.Insp Team Determined That Facility Has Not Established Mechanism for Assuring That Vendor Info Obtained for Key safety-related Components

ML20012E054
Person / Time
Site:	River Bend
Issue date:	03/22/1990
From:	Holahan G Office of Nuclear Reactor Regulation
To:	Deddens J GULF STATES UTILITIES CO.
Shared Package
ML20012E055	List: ML20012E054
References
NUDOCS 9003300011
Download: ML20012E054 (7)

See also: IR 05000458/1989200

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March 22, 1990

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Docket No. 50-458

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Mr. James C. Deddens, Senior Vice President

Gulf States Utilities Company

River Bend Nuclear Group

Post Office Box 220

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St. Francisville, Louisiana 70775

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Dear Mr. Deddens:

SUBJECT:

INSPECTION OF THE VENDOR INTERFACE AND-PROCUREMENT PROGRAMS <

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AT THE RIVER BEND STATION (INSPECTION REPORT:NO. 50-458/89-200)

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This letter transmits-the report of the inspection- conducted October 23 through.

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27, 1989, and November 13 through 17, 1989,= at the River Bend. Station (RBS) by.

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Messrs. R. P. McIntyre, S. D. Alexander, and R. N. Moist of the NRR-Vendor

Inspection Branch and Messrs. I. Barnes, L. E. Ellershaw-and J. R. Boardman'of.

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NRC Region IV.

The inspection was related to plant site activities authorized -

by NRC License Number NPF-47.

At'the conclusion of'the' inspection, our findings,

were discussed with you, Mr. K. E. Suhrke, Manager, Project Management,' and the-

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members of your staff identified in Appendix A= of the: enclosed report.

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The purpose of the inspection was to review the implementation-of the'RBS'

vendor interface program-and the programt for procurement of both safety-related-

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and commercial grade items currently' installed or available for installation in-

safety-related applications. The inspection results indicated that deficiencies

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exist in the areas of procurement and dedication of commercial grade items and

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in the interfaces between RBS and its vendors.

The procurement related deficiencies include failure to

maintain documentation for commercial grade items '(CGIs) properly dedicate and.

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procured for and used

in safety-related applications. ~ The' inspection teamLidentified . numerous -

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instances in which RBS installed'CGIs in safety-related-systems without

adequately evaluating suitability for use in such applications.

In particular,

RBS failed to. perform documented' technical. evaluations to identify attributes

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such as the components' safety functions and critical characteristics,

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verification of design, manufacturing, and material' changes, and receipt'

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inspection requirements beyond a visual examination of identification and

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markings, physical and shipping _ damage, and workmanship and cleanliness. The

inspection team noted that these failures resulted in the use of numerous

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components of unverified quality and qualification in safety-related . .

applications at RBS.

Also, RBS failed to impose on vendors the; provisions 1of

10 CFR Part-21 when the purchase orders required adherence to unique nuclear

specifications.

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Mr. James C. Deddens

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March 22, 1990

The review of the kBS vendor interface program indicated the need for improvement,

especially with repard to the receipt, depth of assessment, and implementation

of corrective actions in response to service and maintenance recommendations

received from the emergency diesel generator (EDG) manufacturers or the current

suppliers of such information.

These manufacturers (suppliers) include

Transamerica Delaval (Enterprise Engine) for the Division I and 11 diesels and

General Motors / Electro-Motive Division (Morrison-Knudsen) for the Division 111

diesel.

For example, RBS failed to receive the appropriate Power Pointers and

Maintenance Instructions pertaining to the Division !!! diesel generator from

either General Motors or Morrison-Knudsen and, therefore, did not evaluate this

technical information for applicability to the RBS Division !!! diesel.

Another deficiency identified in the RBS vendor interface pro ram concerns the

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failure of the Nuclear Licensing group to adhere to procedura requirements

which mandate taking those actions necessary to assure that a timely response

is provided to Nuclear Licensing when incoming correspondence is classified

"For Response Required." As a result of the review of this area, the inspection

team questioned the effectiveness of the tracking system RBS has in place to

monitor the status of evaluation and disposition of incoming technical

information with potential safety significance.

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The inspection team also determined that RBS has not established a mechanism

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for assuring that vendor information is obtained for key safety-related

components such as the EDG. This failure to establish an adequate vendor

interface program contributed to the diesel generator findings discussed

previously.

The inspection findings identified to you during the exit meeting conducted at

RBS on November 17, 1989, and discussed above and in the enclosed report have

been classified as Potential Enforcement Findings 50-458/89-200-01,02,03,and

04(Enclosure 1). The extent to which enforcement action should be taken for

procurement issues is currently under discussion within the NRC. Any enforcement

action in this and other areas identified in this report will be carried out by

the Regional office. We acknowledge the receipt of your letter dated January

25, 1990, in which you described the interim status of your actions for the

four Potential Enforcement Findings.

Region IV will also follow up, as

appropriate, to the actions and information you provided in your January 25,

1990 letter.

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Mr. James C. Deddens

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March 22, 1990

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Should you have any questions concerning this inspection, we will be pleased to

discuss them with you.

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Sincerely,

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Gary M. Holahan, Acting Director

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Division of Reactor Projects III/IV/V

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and Special Projects

Office of Nuclear Reactor Regulation

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Enclosures:

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Potential Enforcement Findings

2.

Inspection Report No. 50-458/89 200

with Appendices A and B

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0FFICIAL RECORD COPY Document Name:

RIVER BEND LETTER

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Mr. James C. Deddens

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Gulf States Utilities Company

River Bend Station

Cc:

Troy B. Conner, Jr., Esq.

Mr. J. E. Booker

Conner and Wetterhahn

Manager-River Bend Oversight

1747 Pennsylvania Avenue, NW

P. O. Box 2951

Washington, D.C.

20006

Beaumont, Texas 77704

Mr. Les England

Mr. William H. Spell, Administrator

Director - Nuclear Licensing

Nuclear Energy Division

Gulf States Utilities Company

Office of Environmental Affairs

P. O. Bcx 220

P. O. Box 14690

St. Francisville, Louisiana 70775

Baton Rouge, Louisiana 70898

Richard M. Troy, Jr. , Esq.

Assistant Attorney General in Charge

Mr. J. David McNeill, 111

State of Louisiana Department of Justice

William G. Davis Esq.

234 Loyola Avenue

Department of Justice

New Orleans, Louisiana 70112

Attorney General's Office

P. O. Box 94095

NRC Resident inspector

Baton Rouge, Louisiana 70804-9095

P. O. Box 1051

St. Francisv111e, Louisiana 70775

H. Anne Plettinger

3456 Villa Rose Drive

President of West Feliciana

Baton Rouge, Louisiana 70806

Police Jury

P. O. Box 1921

St. Francisv111e, Louisiana 70775

Philip G. Harris

Cajun Electric Power Coop. Inc.

Regional Administrator, Region IV

10719 Airline Highway

U.S. Nuclear Regulatory Commission

P. O. Box 15540

611 Ryan Plaza Drive, Suite 1000

Baton Rouge, Louisiana 70895

Arlington, Texas 76011

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Enclosure 1

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Gulf States Utilities Company

Docket No.:

50-458

River Bend Station

License No.: NPF-47

POTENTIAL ENFORCEMENT FINDINGS

During the period of October 23 through 27, 1989, and November 13 through 17,

1989, representatives of the NRR Vendor Inspection Branch and NRC Region IV

reviewed the vendor interface and procurement programs of the River Bend

Station (RBS). As a result of the inspection, and in accordance with the

" General Statement of Policy and Procedures for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1986), the NRC inspection team identified the

followingPotentialEnforcementFindings(PEF):

A.

Potential Enforcement Finding 50-458/89-200-01

The NRC inspectors identified numerous examples of past and present

procurement activities in which RBS installed commercial grade items

(CGis) in safety-related systems without adequately evaluating their

suitability for use in such applications.

RBS procured CGis without

adequately performing and documenting (and failure modes that could

technicalevaluationsto(1)

identify the items' safety functions

effect other safety functions), (2) identify the critical characteristics

needed to ensure performance of safety functions, (3) methods to verify

those critical characteristics under all design and operational

conditions, and (4) determine the effect of design, materia h and manu-

facturing process changes on performance in the intended app,scation(s)

under seismic, environmental, and all other design basis conditions.

In addition, verification of critical characteristics beyond receipt

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inspection for part number, catalog specifications, damage, cleanliness,

and routine pre- or post-installation functional testing was not evident.

RBS relied primarily on like-for-like substitution based on these

attributes. Moreover, RBS had not established verifiable traceability of

CGis to their original manufacturers, upon whose controls and certifi-

cations the dedications were based in part.

RBS also upgraded items

procured as nonsafety-related to safety-related status without adequate

justification and dedication.

These deficiencies in the RBS procurement program and its implementation

resulted in the installation of numerous components of unverified quality

and qualification in safety-related systems in the plant.

Specific

examples identified by the inspection team are detailed in Sections 2.1.2

and 2.1.3 of the inspection report.

The applicable regulation for this PEF is 10 CFR Part 50, Appendix B,

Criterion Ill, " Design Control."

B.

Potential Enforcement Finding 50-458/89-200-02

The NRC inspectors identified several instances in which RBS failed to

impose on vendors the provisions of 10 CFR Part 21 when purchase orders

for items intended for use in safety-related applications specified

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POTENTIAL ENFORCEMENT FINDINGS

compliance with nuclear specifications or quality assurance requirements.

Such procurements were not consistent with the definition of commercial

grade items in 10 CFR 21.3 since they failed to specify the applicability

of 10 CFR Part 21 on nuclear safety-related procurement documents.

Specific examples are discussed in Section 2.1.1 of the inspection report,

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The applicable regulation for this PEF is 10 CFR Part 21, " Reporting of

Defects and Noncompliance."

C.

Potential Enforcement Finding 50-458/89-200-03

The NRC inspectors found that the formal RBS program for the receipt,

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evaluation, and implementation of reconsnended corrective actions for

incoming vendor technical information and NRC generic communications was

not fully effective.

As a result, a significant amount of technical

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information and service recommendations from the manufacturers of the

RBS emergency diesel generators (EDGs) was not evaluated or dispositioned

in a timely manner.

The NRC inspectors also identified several communi-

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cations from other key vendors describing potential safety concerns, which

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RBS received but inappropriately or incompletely evaluated and

dispositioned.

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The NRC inspectors reviewed the RBS interface with the two diesel

generator vendors.

This included a review of correspondence received

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from the vendors and the licensee's disposition of this information.

The inspectors found that, for the most part there were no documented

evaluations of the Transamerica Delaval/ Enterprise Engine Service

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Information Memos (SIMs) pertaining to the Division I and !! EDGs.

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addition, the licensee had not received and was not aware of the existence

of Power Pointers provided by Morrison-Knudsen and General Motors / Electro-

Motive Division for the Division !!! EDG.

EDG vendor correspondence that

was reviewed for applicability to RBS was usually incomplete and/or

inadequate as described in Section 4.3 of the report.

Inadequate

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interface with the EDG vendors was viewed as a significant deficiency

in the RBS vendor interface program.

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The applicable regulation for this PEF is 10 CFR Part 50, Appendix B,

Criterion XVI, " Corrective Action."

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D.

Potential Enforcement Finding 50-458/89-200-04

During the inspection the NRC inspectors reviewed RBS' implementation of

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Nuclear Licensing Procedure NLP-10-006, " Processing and Tracking of

Regulatory and Industry Correspondence" which requires that RBS Nuclear

Licensing take those actions necessary to assure a timely response is

provided to them when the correspondence has been classified "For Response

Required."

The inspectors reviewed approximately 40 RBS evaluations of

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regulatory correspondence, selected based on safety significance and

applicability to RBS.

These included potentially significant deficiencies

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POTENTIAL ENFORCEMENT FINDINGS

in the scram discharge volume, control room ventilation system, and the

emergency diesel generators.

Several of the requested evaluations could

not be provided by the licensee because they had not been reviewed by the

engineering staff. The licensee disclosed that there were 76 outstanding

or overdue regulatory correspondence reviews, 42 of which were f rom the

period 1984 through 1988. The inspectors also questioned the effectiveness

of the tracking system used by RBS for status review and final closecut of

HRC information and other technical information received from vendors.

The applicable regulation for this PEF is 10 CFR Part 50, Appendix B,

Criterion V, " Instructions, Procedures, and Drawings."

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