ML20034B328
| ML20034B328 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/20/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gates W OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9004270020 | |
| Download: ML20034B328 (3) | |
See also: IR 05000285/1989046
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APR 2 0 l990
In Reply Refer To:
Docket: 50-285/89-46
Omaha Public Power District
ATTN:
W. G. Gates, Division Manager
Nuclear Operations
444 South 16th Street Mall
Omaha, Nebraska 68102-2247
Gentlemen:
Thank you for your letter of February 2,1990,_ in responce to our letter and
the attached Notice of Violation dated January 3,1990. As a result of our
review, we find that the following additional information, as discussed with
your Mr. R. Short during a telephone call on April 12, 1990, is needed.
1.
You have indicated with respect to commercial grade procurements for CQE
applications made prior to establishment of your current program, that a
review will be performed of purchases made between January 1,1986, and
April 28, 1988, forcompliancewithrequirements(QAPlanSection4.0and
Procedure QADP-12) that were in effect during that timeframe. However,
the NRC inspection identified five examples where use of these original
requirements resulted in inadequate evaluations of suitability of
commercial grade items for use in safety-related systems. Please clarify-
how additional review using the same criteria will provide reasonable
assurance that essential systems have not been adversely affected.
2.
In your denial of item b. of the Notice of Violation, you have indicated
that availabic documentation for Yokogawa meters provides reasonable
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assurance that no changes have occurred with respect to the design
requirements utilized by General Electric for manufacture of original
meters. Our review of documentation furnished to us during the
inspection revealed that Yokogawa had issued a generic type of
certification, which did not reference the applicability of or
conformance to original equipment seismic qualification requirements.
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The certification was also noted to state, in part, ". . . the finished
products represented by these numbers are fit, form and function
replacements for the General Electric products and in most cases a better
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instrument than the original."
In the absence of other validating
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information, we would not construe that this statement is confirmatory
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that the design of the meters remains unchanged from that utilized for
original equipment manufacture. Accordingly, we continue to consider the
citation in the Notice of Violation to be valid as stated.
RIV:RI:MQPS*
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900427002o 900420
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ADOCK 05000283
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Omaha Public Power District
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It is our understanding from the April 12, 1990, telephone call that you
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will be providing a supplemental response to the Notice of Violation
which will appropriately address the areas required by 10 CFR Part 2.201
as well as the issues discussed above.
Please provide the supplemental information within 30 days of the date of this
letter.
Sincerely,
Original Signed By:
Samuel J. Collins
Samuel J. Collins, Director
Division of Reactor Projects
cc:
LeBoeuf, Lamb, Leiby & MacRae
ATTN: Harry H. Voigt Esq.
'1333 New Hampshire Avenue, NW
Washington, D.C.
20036
Washington County Board
of Supervisors
ATTN: Jack Jensen, Chairman
Blair, Nebraska 68008
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Combustion Engineering Inc.
ATTN: Charles B. Brinkman, Manager
Washington Nuclear Operations
12300 Twinbrook Parkway Suite 330
Rockville, Maryland 20852
Department of Health
ATTN: Harold Borchert Director
Division of Radiological Health
301 Centennial Mall, South
P.O. Box 95007
Lincol:
Nebraska 68509
Fort Calhoun Station
ATTH:
G. R. Peterson, Manager
P.O. Box 399
Fort Calhoun, Nebraska 68023
U.S. Nuclear Regulatory Commission
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ATTN: Resident Inspector
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P.O. Box 309
Fort Calhoun, Nebraska 68023
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Omaha Public Power District
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. U.S. Nuclear Regulatory Commission
ATTN: Regional Administrator, Region IV
611 Ryan Plaza Drive Suite 1000
Arlington, Texas 76011
bectoDMB(IE01)
bec distrib. by RIV:
.R.-D. Martin
Resident inspector
DRSS-FRPS
SectionChief(DRP/C)
MIS System
RIV File
RSTS Operator
ProjectEngineer(DRP/C)
Lisa Shea, RM/ALF
A.Bournia,NRRProjectManager(MS: 13-D;18)
1. Barnes
L. Gilbert
L. E11ershaw
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Omaha Public Power District
1623 Horney Omaha. Nebraska 68102 2247
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402/536-4000
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february 2, 1990
I% @ @ @ 09 $ M
LIC 90-0092
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FEB - 51990
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U. S. Nuclear Regulatory Commission
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Attn: Document Control Desk
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Mail Station PI 137
Washington, DC 20555
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References:
1.
Docket No. 50-285
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2.
Letter from NRC (S. J. Collins) to OPPD (K. J. Morris) dated
January 3, 1990
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Gentlemen:
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SUBJECT:
Response to Notice of Violation (NRC Inspection Report
50-285/89-46)
Omaha Public Power District (0 PPD) received the subject inspection report
(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
for the installation of materials that may have an adverse impact on system
operability requirements. A request was made for a description of actions
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and/or measures assuring that essential systems have not been adversely
affected by replacement of Critical Quality Elements with commercial grade
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items.
The necessary actions to assure that essential systems have not been
adversely affected are addressed in the attachment to this letter.
If yot ;hould have any questions, please contact ine.
Sincerely,
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W. G. Gates
Division Manager
Nuclear Operations
WGG/pjc
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Attachment
c:
LeBoeuf, Lamb, Leiby & MacRae
R. D. Martin, NRC Regional Administrator, Region IV
A. Bournia, NRC Project Manager
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P. H. Harrell, NRC Senion. Resident Inspector
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ATTACHMENT
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RESPONSE TO NOTICE OF VIOLATION
During an inspection conducted on November 27 through December 1, 1989, a
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
violation is listed below:
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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
materials, parts, and equipment that are essential to the safety-related
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functions of the structures, systems, ar.d components.
This requirement has been implemented by OPPD through Procedures GEG-29
and GEI-32.
Both of these procedures require the evaluation of commercial
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grade items for suitability of use in safety-related applications.
Contrary to the above, the following conditions were identified:
a.
Documented 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
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for use in safety-related systems,
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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)
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OPPD Response:
1) The Reas.on for the Violation
if Admitted-
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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
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documented measures for acceptance of Commercial Grade Items for
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
1984.
Guidance was provided to the QA organization via departmental
procedure QADP-12, " Material Acceptance and Receipt Inspection," dated
March 1984,
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Although the methods employed prior to April 1988 were not as
comprehensive as the program in place today, the methods are considered
to have been adequate to assure the quality of materials and the safety.
of the public.
OPPD acknowledges however, that the examples identified in the
violation illustrate that the use 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 S046624 and SO42766
to original equipment qualification was based on a part numbering
convention for GE/Yohgawa 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
document that the materials supplied were the materials ordered.
This
method us 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 th 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.
2) Corrective Stens That Have Been Taken and the Results Achieved
Part a. of the Notice of Violation cited a total of five (5) examples
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of P0 packages with potential problems.
These examples are described
in greater detail in Inspection Report 89-46, Section 4.c. on'
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Commercial Grade Item Procurement Prior to Program Implementation.
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Three of the five examples have been researched and where appropriate,
corrective actions have been taken.
The other two examples are
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addressed in Section 3 of this response.
Results of the research are
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summarized below.
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Item 4.c.(1) P0 C097855, see Section 3 " Corrective Steps That Will
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Be Taken To Avoid Further Violations."
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.
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It has been determined that 278 of the 500 bolts have been issued
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from the FCS warehouse, of which 10 were installed in 5 CQE
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conduit supports under modification MR-FC-86-ll7 and 268 were-
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installed in non-CQE applications.
222 bolts remained in the
warehouse which have been * HOLD" tagged to restrict their use.
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Commercial Grade Dedication package has been prepared in
accordance with the current guidance of PED gel-32.
The package
required metallurgical testing of a representative sample of the
bolts.
This testing has been conducted. A sample of 25 bolts was
shipped for testing to Taussig Assochtes, Inc. of Skokie,
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.
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 SBM 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.(4) P0 S019921 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
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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
applications purchased before. April 1988 (i.e., before implementation
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of the current extensive program) are acceptable for continued use, all
commercial grade purchases for CQE applications between January 1, 1986
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and April 28, 1988 will be reviewed for compliance with the
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requirements of QA Plan Section 4.0 and QADP-12 that were in place at
that time. This review will include P0 #C097655, dated March 20, 1987,
to Great Plains Industrial Supply Company (item 4.c.(1) of Reference 2)
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and PO #S012973 dated October 3, 1986 to Satin taerica Corporation
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(item 4.c.(5) of Reference 2).
The. review wil', be documented and any
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
1, 1986 commercial grade procurement fer CQE applications were
comparatively infrequent,
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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.
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4) Date When Full tomo 11ance Will Be Achieved
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In that the current CGD program closely follows the guidelines'of EPRI
NP-5652 " Guideline for the 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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