ML20127F641
| ML20127F641 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 05/03/1985 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20127F608 | List: |
| References | |
| 9766N, NUDOCS 8505200551 | |
| Download: ML20127F641 (20) | |
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N Commonwealth Edison j
f One First Nationti Plaza Chicago. Ilknois
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'T Addr ss RJply to: Post Offica Box 767 L-
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/ Chicago, Illinois 60690 May 3, 1985 n
Mr.damesG.Keppler,RegionalAdministrator
' Directorate of Inspection and
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Enforcement ~- Region III U.S. Nuclear Regulatory Commission-
-799 Roosevelt Road Glen Ellyn, IL. 60137
Subject:
Dresden Station Units 1 and 2 LaSalle County Station Units 1 and 2 Quad Cities Station Units 1 and 2 Zion Station Units 1 and 2 Response to Inspection Report Nos.
50-373/84-25, 50-374/84-32; 50-237/84-15, 50-249/84-14; 50-254/84-15, 50-265/84-13; 50-295/84-19, and 50-304/84-20
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. R.
Hasse & W. Kropp on August 15-16, 30-31, September 5-7, 11-12, 18-21, 25-27, October 10-11,'31, November 15 & December 7,1984 of activities at a number of Commonwealth Edison plants. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company. response to both the noncompliances and unresolved items are provided in the enclosure.
We have reviewed the non-compliance items and have prepared a response to each item. The same is also true for each of the unresolved items. Where necessary, appropriate corrective actions were taken and these actions will be completed this month. _ In certain specific instances the example identified by your staff was reviewed and facts presented which we believe resolves the specific concern.
We are prepared to discuss this response with your staff at their convenience. If you have any furthur questions on this matter, please direct them to this office.
Very truly yours, O
L. O. DelGeorge Assistant Vice President im cc: NRC Resident Inspector - LaSalle NRC Resident Inspector - Quad Cities rkA7 6 1985 NRC Resident Inspector - Dresden NRC Resident Inspector - Zion 9766N 8505200551 850515 PDR ADOCK 05000237 G
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RESPONSE-TO NOTICE OF-VIOLATION CommonwealthEdison. Company Dresden Station Units 2 and 3 Quad Cities Station Units 1 r.nd 2 h
Zion Station Units 1 and 2 As a. result of the NRC inspection conducted August:15-16; 30-31~;
September 5-7,~ 12,- :18-21, 25-27; October 10-11, 31; Novenber 15,- and
' December 7,-1984, the following alleged violations were identified:
A.
10 CFR 50, Appendix B,-Criterion II, as implemented by Commonwealth Edison Quality Requirement 2.0, requires the QA program to be. documented by
-written policies,-procedures and instructions and that it be carried out.
-in.accordance:with these policies, procedures, and instructions.
Contrary to the above,-procurement activities at Quad Cities, Dresden and (Zion, have not been carried'out in accordance with certain policies, procedures or instructions defined in the licensee's QA Manual. Specific examples are as~follows:
ITEM A.1
. Spare parts and replacement items, equipment and components were not J
purchased to equal or better requirements than those originally specified as
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required by Quality Requirement l(QR) 7.0 " Control of Purchased Material,
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Equipment and Services".. Items not procured to equal or better requirements
-include a safety injection pump (Zion), 3" gate valve for the RCIC turbine (Quad Cities), and discs for the main steam isolation valves (MSIV)'(Quad Cities).-
Commonwealth Edison Response to Item A.1
' Commonwealth Edison does not fully agree with the Statement of Noncompliance related to the Zion safety injection pump and Quad Cities MSIV disc. CECO agrees the gate valve issue at Quad Cities was incorrectly done.
As discussed elsewhere in this response, we believe our practice of procuring '
spare parts by part number / drawing nunber 'is adequate to assure-replacement l
parts constructed by original: equipment manufacturers to quality requirements equivalent to that originally provided.
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.. Review of P.O. 266652 to Pacific Pump for a safety injection pump at Further
-Zion disclosed the reference in the description to drawing J-287.
review of this drawing showed the Westinghouse SPIN number which can be traced Thus, we to the original specification for the Zion safety injection pumps.
266652 believe that adequate information was provided to Pacific Pump in P.O.
to establish the technical requirements and permit them to supply a replacement pump equivalent to those originally supplied. The procurement in question is solely attempting to purchase an identical spare component. However, due to questions regarding the Quality Assurance Program to which the pump wasc request Z-38275 has been written to completely disassemble, inspect, balance, All work.
'and reassemble the pump to verify its quality and acceptability.
. associated with Z-38275 was satisfactorily completed. The pumpt was-tested in early April and met all test requirements. As to the QA program, this issue is discussed in part as part of Item C.l.
Our review of P.O. 289415 to Crane Co. for MSIV discs and stems at
- Quad Cities has disclosed a typing error in that Crane drawing OR 34289 was not included in the part description for either the disc or stem although it is included in the description on the stores inventory card for each item.
However, this minor deficiency proved insignificant in that the Crane Co.-
order acknowledgement properly identified not only DR 34289 as the valve assembly drawing but also identified the Crane Co. proprietary manufacturing drawings and non-destructive examination requirements for the parts to be The non-destructive examinations specified in our purchase order provided.
and confirmed via Crane's order acknowledgement match the requirements of GE Specification 21A5644. As a result, we believe the MSIV discs and stems were acceptably specified and procured.
Investigation into P.O. 288585 for a 3" gate valve at Quad Cities shows that it has not yet been received from Crane Co. However, broader investigation identified two additional purchase orders (251693 and 740577) for identical valves with the same concern. In 1980, a valve was bought to replace the 2-1301-16 valve. Station tOclear Engineering evaluated this replacement valve purchased under P.O. 730605 as being acceptable with a magnetic particle examination of body and bonnet as opposed to the originally required radiographic examination. This was intended as a one-time exception to the original specification (R-2358) requirements. However, this exception was carried forward in the Station's inventory system to P.O.'s 251693, 740577, and 288585. The valve purchased under 251693 is currently on hold (hold tag 84-550) pending resolution. Two valves were purchased under P.O.
One was installed in the Unit 1-220-1 position and its long term 740577.
acceptability is being determined by Station Nuclear Engineering.
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We are confident that it ~will'be determined acceptable for reasons similar to those discussed for the Unit 2 1301-16 valve in 1980.- The second valve on that order is_on hold (hold tag 84-551). A change order to P.O. 288585 was
. processed-to add the radiography requirement, and the Stores' item description was revised at Quad. Cities _.to: prevent reoccurrence of the ordering error.
Aside from the radiography / magnetic particle issue just discussed, concern is raised by NRC that the purchase order does not establish codes, standards," welding requirements and NDE requirements. The valves in question are Crane Co.'s standard product, a commercial grade item selected and procured for use on the basis of. the published catalog information. We have determined that these model.787U valves meet ~our 831.1 design application. Crane's
~ published literature for these valves indicates compliance to ANSI B16.34.
816.34Property "ANSI code" (as page type) with input value "ANSI B16.34.</br></br>816.34" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. is referenced in ANSI B31.1 as an acceptable standard for valves.
-B16.34 also includes acceptance criteria for radiography, liquid penetrant, and macyietic particle examinations. - Further, Crane Co. has developed NDE
- procedures including acceptance criteria meeting-the B16.34 standard. 'In lieu of. specifically imposed acceptance criteria that differs from B16.34, Crane's standard manufacturing procedures are implemented when POE is required. As a'
. result, we believe all of these valves are technically acceptable and do not suffer-from a quality requirement deficiency. However, the " Suitability of Application" of these valves without radiographed bodies and bonnets will be determined-at the' time'the designated use is established as will the need for^
such radiography.
Althoucfi the ordering error on the 3" gate valve at Quad Cities is considered an isolated case, we have decided to take the following additional'
, : measures:
Corrective Action Taken to Prevent Recurrence A memo to the Quad Cities Maintenance and QC personnel will be
. preparing detailing this specific incident and reaffirming the need to always
.use the original' procurement' documents when ordering spare parts.
Date When Full Compliance Was Achieved The memo will be distributed by May 15, 1985.
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Purchase orders did not' require the supplier to submit theira nonconformances:which were dispositioned "use-as-is" or " repair"las required;
. by QR 15.0 (" Nonconforming Materials,' Parts or Components and Operations") ~ and -
. Quality Procedure (QP) 4-51 (" Procurement Document Control for-Operations -
Processing Purchase Documents"). Items procured in which the purchase order
'did not require the submitte.1 of supplier's nonconformances included. a safety Jinjection pump (Zion), -3" gate valve for the RCIC turbine. (Quad Cities), and discs:for the MSIV (Quad Cities)..
L orrective Action Taken and Results Achieved C
x QP 4-51,.the rinament which provides the process procedure for
. procurement has required that when engineering requirements are included in the. purchase requisition, a statement is required to be added to the purchase order requiring that nonconformances with CECO engineering requirements shall be promptly submitted to CECO in writing for resolution. While we do not perceive this apparent oversight to have led to a degradation of the quality
- of parts to be provided in the:past this requirement will be. imposed on futuresafetyrelatednon-commercialgradeorders. To provide further.
guidance for Quality Control and Qualit'y Assurance,'a Purchase Request Review
. Checklist,-QP 4-51.3 was added as part of a November 21, 1984_ revision to this
- procedure to ensure inclusion of the relevant procurement requirements.
In addition, the statement in Attachment A to QP 4-51 to be included in the purchase requisition relative to nonconformances when engineering requirements;
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are included was' clarified in the November 21, 1984 revision..This clarifica-tion provides nonconformances that cannot be resolved to Commonwealth Edison
~ Company engineering requirements shall-be submitted to the Commonwealth Edison Company in writing'for review and disposition.
Corrective Action Taken to Prevent Recurrence
' To prevent recurrence, additional revision to these two steps was written in the March 13, 1985 revision to QP 4-51 which also requires that Quality Control and Quali,ty Assurance shall verify that the various applicable statements of Attachment A of-QP 4-51 are included in the Request for' Purchase.
Date When Full Compliance Was Achieved Full compliance was achieved with the March 13, 1985 revision to Attachment A of QP 4-51.
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. ITEM A.3 Purchase orders did not invoke on the supplier, the responsibility to review commercial grade or previously approved safety-related materials, parts and equipment for their suitability of application as required by QR 4.0 (Procurement Document Control"). Items that were procured in which the review for suitability of application was not imposed on the supplier included Agastat time relay (Zion), 3" ball valve (Zion), pressure regulator for the diesel engine (Zion), Agastat auxiliary relay (Dresden), motor for the HPCI auxiliary oil pump (Dresden), strip chart recorders (Dresden), 175 amperage breaker (Quad Cities).
Commonwealth Edison Response to Item A.3 We interpret the suitability of application requirement to apply to suppliers of safety-related items to provide assurance that they have reviewed the suitability of any commercial grade parts in the assembly they are providing. The suitability of application for purchases of commercial grade items by Commonwealth Edison is made by Edison at receipt inspection or at the time of installation via the work request system and is verified by quality control prior to return of the equipment to service. The imposition of review of " Suitability of Application" on commercial grade suppliers is not meanirgful within our system because the end application of the part or item would not be known by the supplier and may not be established at the time of procurement.
However, review of the specific examples cited has caused the 175 amp breaker at Quad Cities to be replaced during the course of this inspection and prior to issuance of the inspection report. The Dresden HPCI auxiliary oil pump motor has not yet been received but will be seismically evaluated prior to declaring it acceptable for use. The other examples herein were reviewed by the respective Stations and the Station Nuclear Engineering Department, as appropriate, and they were determined to be acceptable for the intended service.
Although we believe CECO has properly met the requirements of QP 4.0, in order to resolve the difference between QR 4.0 and QP 4-51 Attachment A to QP 4-51 was revised on November 21, 1984 to include this requirement of QR 4.0 as follows:
"The vendor is required to review for suitability of application of commercial grade or previously utilized materials, parts and equipment."
This statement is required to be included in future safety-related purchase orders except those which are safety-related commercial grade after January 21, 1985.
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' Purchase orders for a safety injection pump (Zion), 3" gate valve for
sidentify those records,- indicative of quality, which were required to be-eubmitted and the method:of. disposition of those records which the vendor-retained as required by.QR 4.0 (" Procurement-Document Control"). Examples of~
records not identified in the purchase orders for retention by the supplier.or
-submittal'to the licensee included nonconformances, radiographs, weld procedures, and POE procedures.-
Discussion
. During initial construction or major backfit projects, components are procured from vendors in accordance with Equipment Specifications prepared by our_ Engineering Department or Architect-Engineer. These specifications define L
cthe documents required to be submitted with the component to verify its
. adequacy and also address retention requirements of supporting documentation.
The inposition of supporting documentation retention requirements is
- not' applicable for catalog type commercial grade items as these items are a
= manufacturer's standard product. These are items that are typically manufactured to established designs or standards cad may even be "off the shelf" at the time of purchase. The procurements tc which document' retention is meaningful are those for non-commercial grade components or safety-related parts for those components. Our practice has been to identify these parts or components by part number, drawing number, shop order nunber, etc. to identify them with the original procurement and its requirements. Our experience over the years has not disclosed much evidence of the need to return to these -
. vendors to retrieve this supporting documentation and, as a result, we do not believe that failure to define document retention requirements on individual parts orders is significant. Our.eview of the three examples cited disclosed that the records we desired to be submitted to verify acceptability were delineated on the procurement documents. However, we concede that this is not L
an all inclusive list of documentation available to verify quality and we i
fully expect the vendors to retain the supporting documents in accordance with l
original specification requirements;or their normal business practices.
l Corrective-Action Taken-to Prevent Recurrence l
l To resolve this NRC concern Attachment A to QP 4-51 was revised on November 21, 1984, to include the following statement:
" Records which are not to be submitted with this procurement but which are required to provide evidence that an activity was performed in accordance l
with applicable requirements shall be maintained by the vendor. Disposal l
of such Wants shall not be done until the Purchaser has been afforded
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the opportunity to take the documents from the vendor for its own retention."
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This statement is required to be included in future safety-related
. purchase orders except those which are' safety-related commercial grade after January 21, 1985.
Date When Full Conollance-is Achieved Full Compliance has been achieved with the November 21, 1984 revision.
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. ITEM A.5 Purchase orders for a safety injection pump (Zion), 3" gate valve for the RCIC turbine (Quad Cities), and discs for the MSIV (Quad Cities), did not require the submittal of special process procedures for evaluation as required by QR 9.0 (" Control of Special Processes").
Commonwealth Edison Response to Item A.5 We do not agree with this exanple as being an item of noncompliance.
As previously described, our initial construction, major modification, or major backfit component procurements are usually governed by Engineering Specifications which, as deemed necessary for engineering control reasons, include Special Process Procedures submittal and approval requirements. The main purpose for requiring such submittals is to coordinate the overall initial design process. Otherwise, the Special Process Procedures are established under the vendor's Quality Assurance Program and applicable National Standards or Codes to meet design requirements. Verification that such certification is acceptably performed is achieved through inspection, surveillance and audit activities at the vendors' facilities as is the case for the other requirements involving procurements.
The provision in our Quality Assurance Program in Quality Requirement, Q.R. 9.0, for Process Control Procedures of vendors to be submitted to Commonwealth Edison Company for review and evaluation, applies to new projects and major new modifications where coordination of the total initial design by the responsible design organization is needed. Procurements of replacement items are structured on the basis of supplying items equal or better than those originally supplied and of maintaining the quality of the component at least equal to those originally supplied. Items are identified to the Original Equipment Manufacturers (OEM) by item, drawing, specification, or shop order number, etc. to provide identification and traceability to the item originally furnished. We believe this approach is adequate to assure replacement parts or components are supplied to original requirements without re-submittal of procedures for approval. In the case of the three procurements cited, they were replacements in an already designed system and no special consideration as to special process procedures were deemed needed. As an added precaution and to provide added assurance, Attachment A of Q.P. 4-51 was revised on November 21, 1984 to provide that a statement be included in the purchase order that the OEM is required to certify that items being procured for safety-related application are equal to or better than the items originally provided.
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, B.
10 CFR 50, Appendix B, Criterion III, as implemented by Commonwealth Edison Quality Requirement 3.0, requires that safety-related parts and equipment be reviewed for suitability of application.
Contrary to the above, the Region III inspector identified the following examples at Quad Cities and Dresden where an adequate evaluation for suitability of application was not performed:
ITEM B.1 A breaker for the reactor protection system was installed without evaluating the significance of "N" which was missing from the model number.
The "N" identified the breaker as nuclear grade.
Commonwealth Edison Response to Item B.1 General Electric's RPS protective relay seismic upgrade spare parts retrofit package quotation #416-5556-EB2/EB3/EE1/EE2 dated April 26, 1982, indicated the 175 amp circuit breaker was non-safety related. Notwithstanding, P.O. #501632 dated April 5,1984 for 3 circuit breakers indicated the circuit breakers were ordered safety related, commercial grade and 10CFR Part 21 not applicable. The technical evaluation that resulted from the new breaker not having the suffix "WLN" on the part number addressed only the WL (with lugs) as meeting our requirements. However, the "N" was discussed with our supplier, General Electric Supply Co. who discussed it with the General Electric Distribution Equipment Div. in Plainville, Connecticut who advised that the "N" was not necessary and should not be used in the future.
In retrospect, had GE-San Jose correctly identified the breaker as nuclear grade or had GE San Jose been approached on the "N" suffix question, the improper installation would not have occurred. As immediate corrective action, the EPA was removed from service and a breaker with the "N" (Nuclear Grade) suffix was installed.
The classification of these circuit breakers in our Stores Item record system has been changed to safety related, 10 CFR Part 21 applicable, to ensure all future orders are properly classified.
We consider this misselassification an unique and isolated case. For added assurance, a memo will be sent to each Station discussing this event and reminding Station personnel not to accept and OEM's classification but to perform a completely independent classification review.
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Y L. ITEM B.2 A 40 W Motor for the HPCI auxiliary oil pump was procured without an evaluation of the seismic capability of the motor.
Commonwealth Edicon Response to Part B.2 The 40 HP WCI auxiliary oil pump motor procurement initially began with intent of buying an identical replacement. During the quotation process it was noted that the original motor was no longer manufactured but an alternate equivalent motor was offered. This alternate motor was evaluated by engineering and determined to be acceptable although the evaluation process in August, 1983 was not as formalized or documented as it is today. Seismic requirments were not specifically required for this motor.
This motor has not yet been received at Dresden. Prior to accepting this motor via receipt inspection a seismic evaluation will be performed to determine its acceptability for use. The investigation into this item also disclosed a 7 1/2 W HPCI emergency oil pump motor in stock that had been commercially procurred without seismic evaluatioa requirements. This motor has been placed on hold status and will reautre sei.tmic evaluation prior to use.
Newer procedures, in place since the original order was made, would have better documented the differen:.:es in designs and should have properly resolved these df/ferences. Therufore, no additional correction action is considered to be necessary.
ITEM B.3 A 3" gate valve was procured with new technical requirements which were not established through a documental design change process.
Connonwealth Edison Response to Item B.3 Our response to this item is encompassed in Item A.I.
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. C.
10 CFR 50, Appendix B, Criterion VII, as implemented by Commonwealth Edison Quality Requirement 7.0, requires measures to be established to ensure that purchased material, equipment, and services conform to the procurement documents.
Contrary to the above, at Zion, the licensee failed to ensure that a safety injection pump conformed to procurement documents, in that it was received and accepted with the following deficiencies:
ITEM C.1 The vendor certified the pu@ was manufactured to his non-ASE QA Manual which had not been approved by Commonwealth Edison.
Corrective Action Taken and Results Achieved The Commonwealth Edison Quality Assurance Department conducted an audit at Pacific Pumps (Dresser) in November 1984 to assure implementation of the Non-Code, Safety-Related Quality Assurance Program during the manufacture of the Zion Safety Injection Pump. The program was found to be implemented during the period of manufacture. An evaluation of Pacific Pumps, Non-Code, Safety-Related Quality Assurance Program was completed. Deficiencies noted in their Quality Assurance program have been resolved and the QA program was approved by Commonwealth Edison.
In order to accept the pump itself the following items have been or performed along with the aforementioned items related to their Quality Assurance program:
a) Pump serial nurters were verified.
b) A vendor representative was brought in to assist in disassembly, inspection, and reassettly of the purrp, c) Dimensional checks were performed on the purrp.
d) Inspection / calculations results were reviewed with the Station Nuclear Engineering Department (SNED).
e) Discrepancy Records (DR's) initiated have been resolved and closed.
After installation and prior to complete return to service, a preoperational test was conducted to assure proper pump capacity as well as i
functionally check the pump. The pump satisfactorily completed all test requirements in early April 1985.
Corrective Action Taken to Avoid Further Noncompliance Zion QA and QC personnel were reinstructed to properly identify a vendor's QA program in the purchase requisition. Furthermore, QP 4-51 was revised on Noverrber 21, 1984 to include a Purchase Request Review Checklist (Form 4-51.3). This checklist required proper verification of the applicable QA program and revision among other requirements.
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. Date When Full Compliance Will Be Achieved Full Compliance has been achieved with the training of Zion personnel and QP 4-51 revision.
ITEM C.2 The radiographic reader sheets for the pump shell were not received with the documentation which accompanied the shipment.
DISCUSSION A radiographic inspection report was included in the documentation package which accompanied the pump. It was incorrectly assumed that this report represented all that was going to come from the vendor. This report did not address the radiography of the castings themselves.
CORRECTIVE ACTION TAKEN AND RESILTS ACHIEVED The casting reports and the RT's themselves were requested and received The vendor had in fact performed the radiography, but omitted including all of the reports in the original documentation package.
CORRECTIVE ACTION TAKEN TD AVOID REOCCURRENCE To help prevent reoccurrence, all Zion QC and QA personnel have been retrained in all aspects of Safety-Related/ Code Related Receiving Inspections.
Also, QP 10-54 was revised November 21, 1984 to state the limits of acceptance of items solely by receipt inspection as provided in ANSI N45.2.13. These limits also were included as information in QP 4-51 in a revision dated March 13, 1985.
In addition, the scope section of QP 4-51 was revised January 9,1985 to require reference to ANSI N45.2.13 and Section III of the ASME Code, as applicable for additional procurement control details.
DATE MEN FULL COWLIANCE WILL DE ACHIEVED Zion Station is currently in full compliance.
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ATTACHENT B RESPONSE TO UNRESOLVED ITEMS Unresolved Item No. 1 Commonwealth Edison Corporate Procedure QP 4-51 permits the procure-ment of safety-related parts, items, components and equipment from suppliers who do not have a QA Program, providing the original item (which is being replaced) was purchased in the same manner. The procedure also permits the procurement of items from suppliers who are not on the Approved Bidders List (ABL) because they no longer maintain an acceptable QA program. Procurements of safety-related items from both types of suppliers are required to meet specified criteria, as defined in the licensee's procurements QA procedures.
These criteria are as follows:
a) the item is procured "like for like" relative to the item it is replacing; b) The original equipment manufacturer (OEM) is the supplier of the item bring procured; and c) an evaluation is conducted to ensure that interfaces, interchangeability, safety, fit, and function are not adversely affected or contrary to applicable regulatory or code requirements.
These three criteria are not sufficient to ensure that items which are not simple in design (i.e., RHR pump, MSIV etc.) are of acceptable quality when they are supplied by a vendor having either an inadequate or no QA program. (Unresolved Item No. 50-373/84-25-01 et.al.)
Commonwealth Edison Response to Unresolved Item No. 1 Historically at Commonwealth Edison, spare and replacement parts have been procured from the OEM whether or not he maintained a QA Program due to the fact that he was the only technically capable source of supply of the required part. Although the three criteria stated in the inspection report (like for like, OEM, technical evaluation) have been a requirement of our QA Program for quite some time, our methods of implementing the requirement of a technical evaluation has changed significantly in recent years.
Initially, this evaluation took the form of a determination of required documentation to be supplied with the part and was signified by initials of the evaluators on the stores requisition card. As a result of the Dresden drywell to torus vacuum breaker packing non-compliance corrective action, I.E. Inspection Report No. 50-237/83-17, the technical evaluation requirement grew more formalized at each of our stations and evaluation procedures were generated.
The Noverrber 21, 1984 revision to QP 4-51 Attachment A amplified the wording regarding the " care to be exercised to assure at least equivalent performance" and provided the requirement for a documented technical evaluation at the time of receipt inspection.
Our initial evaluation at the time of the procurement from an OEM will consider not only what tests or inspections are required as part of the receipt inspection process but will also determine whether documentation beyond a Certificate of Conformance is to be provided to document acceptability.
QA program,y, for components being procured from vendors without an approvedour evalu Additionall audit or source inspection.
4 s Unresolved Item No. 2 Commonwealth Edison Corporate Procedures QR 4.0 and 7.0 describe three methods which can be used to accept safety-related items from approved suppliers; namely, certificates of conformance, source inspection, and receipt inspection. The procedures do not provide definitive guidance relative to use of each. ANSI N45.2.13-1976 provides specific requirements regarding this issue.- (373/84-25-02; 374/84-32-02; et.al.)
Commonwealth Edison Response to Unresolved Item No. 2 Method of acceptance of any safety-related item hinges on its degree of complexity. ANSI N45.2.13-1976 does not specifically define " complex".
The word is used in Section 10.3.1 but not defined. Sections 10.3.2 and 10.3.3 imply an item is not complex if the item is "relatively simple and standard in design, manuTa'cture and test." In general, the procurement of spare and replacement components and parts to existing designs implies simple and standard design and established manufacturing and test programs.
For suppliers who have been placed on the Approved Bidders List (ABL) for safety-related work, the r,stablished programs of audits and surveillances is adequate to meet the requirements of ANSI NAS.2.13-1976, Section 10.3.1.
A supplier on the Approved Bidders List for safety-related work must have a complete Quality Assurance Program which has been reviewed and approved by Commonwealth Edison, and must have a technical evaluation of their capability to supply the specific category of items on the ABL.
Periodic audits and surveillances are intended to verify the suppliers implementation of their entire 18 element (10 CFR 50, Appendix B) quality assurance program. If applicable to the suppliers scope of supply, these audits and surveillances include verification of the items recommended in ANSI N45.2.13-1976, Section 10.3.1.
QP 4-51 was revised to prcvide for determination and documentation of the need for source verification, t,ased on the complexity associated with the work activities for the item procured by audits, surveillances, hold points or witness points. QP 4-51 Attachment A will be revised to clarify the elements of the evaluation made prior to placement of the order. Also, QP 10-54 was revised to include the provisions of AllSI N45.2.13 for acceptance of procured items solely by receiving inspection.
Further, although not documented as part of the procurement activities, we perform post-maintenance testing of systems and conponents to demonstrate operability and proper function upon their return to service. As a result, we do not place sole reliance on a nanufacturer's Certificate of Conformance to demonstrate adequacy of a part. However, the many recent changes to QP 4-51 will enhance our source inspaction activities and provide greater depth to our program to ensure the acceptsbility of such safety related item procurements.
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, Unresolved Item No. 3 Commonwealth Edison Corporate Procedure QP 4-51 states that the procurement of pipe, valves and pipe fittings may be treated as commercial grade when (1) the item is a "like for like" replacement or (2) special safety-related considerations (seismic, radiation, LOCA, environmental, etc.)
are not required as part of the procurement.
Strict interpretation of this statement could result in the procurement of valves and piping as commercial grade because they are "like for like", even though they do not meet the definition of commercial grade in 10 CFR 21.
(0 pen items 373/84-55-03; 374/84-55-03; et.al.)
Commonwealth Edison Response to Unresolved Item No. 3 QP 4-51 was revised on November 21, 1984 to change "or" to "and" so as to eliminate a possible interpretation which could result in the procurement of valves and piping as commercial grade because they are "like-for-like",
even though they do not meet the definition of commercial grade in 10 CFR 21.
We have found no evidence of improper procurement due to misinterpretation of this section of QP 4-51.
Unresolved Item Ho. 4 At present, a review is underway at Commonwealth Edison operating plants to ensure proper classification of spare / replacement parts which are procured nonsafety-related and then used in safety-related components. An inspection of this process at LaSalle indicated that many parts are being reclassified from nonsafety-related to either " safety-related" or safety-related commercial grade".
In each of the five reclassifications reviewed, the status of existing parts were upgraded based on (1) part nunt)er verifica-tion (like-for-like) and (2) an assessment of the part condition. This approach is acceptable for items which are simple in design, manufactured with proven processes, or will be subjected to testing for acceptability after receipt. For all other items, an evaluation should be conducted to determine those technical and quality requirements which are critical to the application of the item.
(Unresolved Item No. 50-373/84-25-04 et.al.)
Commonwealth Edison Response to Unresolved Item No. 4 As a result of previous inspections which questioned the classifica-tion of items at the part 1cvel, we have undertaken a part classification review process at each of our operating plants. Since many of these parts were originally classified several years ago to a much less developed classi-fication criterio/ process than exists today, we find many parts in need of
.-. reclassification and upgrade to a " safety related" designation.
For the most part, however, the parts being upgraded are truly " commercial grade" items in that they are not specifically designed for licensed facility application, they are used in other than licensed facilities and they are catalog type items. These are also parts that during our original classification process were determined to be non-safety related and, as such, required no documenta-tion, QA Program for manufacture, etc. During this initial classification process, pressure boundary items, ASME Code items, and items determined to be safety related by application were classified / designated as safety-related and were provided with appropriate. documentation. While we believe the current process of upgrading parts originally classified as non-safety related is
-adequate and appropriate, additional guidance will be provided including the consideration of testing as an element of the classification or designation process.
Unresolved Item No. 5 The licensee's QA program provides a definitior, of commercial grade items which is compatible with that in 10 CFR 21; however, neither the QA program nor the implementing procedures address the dedication process for an item which is procured arid received as commercial grade.....
.The inspector is concerned about (1) the general lack of prescrip-tiveness with regard to the dedication process of commercially procured items and (2) the lack of objective evidence to support the Agactat relay's seismic characteristics for suitability of application.
(373/84-25-05; et.al.)
Commonwealth Edison Response to Unresolved Item No. 5 For the purposes of Part 21 reportability, safety-related commercial grade items are dedicated upon receipt and tagging at the station.
Depending on the circumstances of the procurement, a determination of suitability of application occurs at different times.
In the example given,
- he Agastat relay was procured safety related - commercial grade and the
.suitability of application process took place at the time of purchase. These relays are installed in the Auxiliary Electric Room at Dresden Station in the ADS ckcuitry. The Auxiliary Electric Room is considered a mild environment and is located on the ground floor, elevation 517'-6".
The relays are mounted to the panel with relay sockets which are held with two 10-32 machine screws, lock washers and hex nuts and is considered to be rigidly mounted. The relay is held to the socket with an ECR0155001 heavy duty mounting strap. These sockets and locking straps are the same as identified in the manufacturer's seismic test program. The panels are rigidly mounted to the floor. The required response spectrum for this level has a zero period acceleration of
.2g's.
The fragility level shown in the manufacturer's test report for a nonenergized relay shows 3 g's zero period acceleration and a 10g test response for the relay in the energized and transitional modes.
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. This panel was supplied as original equipment for the plant from General Electric. The panel has, also as original equipment, General Electric HFA relays, used in safety-related applications for the ADS circuitry.
Documentation from General Electric shows these relays to be qualified for a zero period acceleration of 3g's for a normally open contact with the relay deenergized, and a 2g's for the normally closed contacts.
Therefore, the use of these relays is considered to be adequate for use in this application and is not indicative of a lack of prescriptiveness. The engineer procured a commercially available relay that met his design require-
.nents and therefore obtained safety-related commercial grade item with a known end use.
However, the typical suitability review of safety related commercial grade items takes place at the time of use. For example, parts with multiple applications at the station such as valves, packing, relays, switches, etc. are procured as safety related commercial grade items, received with documentation via receipt inspection and are stored as safety related items pending determination of end use. The review takes place within the Maintenance Department during the work request process. During this process, Maintenance is responsible for proper selection of parts or components to maintain the quality of installed items as like for like or better. Quality Control is responsible to verify proper selection of parts prior to return-to-service of the equipment. Further, if non-safety related parts are needed in a safety related component, a part classification review is required to either confirm the adequacy of the non-safety related determination or to provide the basis for upgrade. This reclassification is completed prior to return to service of the equipment. Finally, post maintenance testing is performed either as a functional demonstration or in accordance with an approved procedure to verify adequacy of not only he parts but the work performed. We believe our system provides adequate review to ensure suitability of application of commercial grade items for safety related use.
Unresolved Item No. 6 Commonwealth Edison Corporate Procedure QP 4-51, (Attachment A), and 10 CFR 21, define a commercial grade item as an item that is (1) not subject to design or specification requirements that are unique to nuclear facilities and (2) used in applications other than nuclear facilities and (3) can be ordered from the manufacturer on the basis of specifications set forth in a catalog.
The following three safety-related commercial grade purchase orders were issued for items which are subject to design and specification requirements unique to nuclear facilities:
l_.
PO 290566 - Motor for W CI auxiliary oil pump which required seismic qualifications.
2_.
PO 266308 - Recorders for suppression pool temperature monitoring which required seismic and environmental qualifications to IEEE 344 and IEEE 323.
3.
P0 501632 - 175 ampere breaker which required seismic and environmental qualification to IEEE 344 and IEEE 323.
. Although other purchase orders which were reviewed and properly classified, the inspector is concerned if the classifications are always accomplished in a consistent manner. This matter is considered an unresolved item pending further review. (Unresolved Item No. 373/84-25-06 et.al.)
Commonwealth Edison Response to Unresolved Item No. 6 The apparent concern involves the consistency with which the Part 21 classification is made and revolves around differing interpretation of the statement " design or specification requirements unique to nuclear facilities" in Part 21. The November 21, 1984 revision of QP 4-51 has now defined design or specification requirements unique to nuclear facilities to include seismic, radiation, and environmental and has provided an alternate documented evalua-i tion method by which commercial grade items may be determined to meet these design requirements. However, QP 4-51 specifically requires harsh environment items to be procured with 10 CFR 21 applicable. We believe this revision provides adequate guidance to permit consistent 10 CFR 21 determinations to be made.
i Unresolved Item No. 7 l
Purchase Order 289415 (MSIV discs and stems) did not explicitly invoke requirements which are equal or better than those in the original specification.
Licensee personnel stated that they believed the drawings referenced in the purchase order adequately referenced the original requirements. On November 15, 1984, the NRC inspectors visited Crane Valve Company in Ambridge, PA, to i
i determine if the valves were manufactured to requirements which are equal to or i
better than those in the original specification. The following observations were made:
- 1) The manufacturer could not identify the drawing referenced in the purchase order for the discs (Drawing No. C4063). The plant manager noted that in the past, the valve discs were manufactured from a single casting. The current design consists of two pieces; a casting and a guide tube. The inspectors were unable to verify the original design.
- 2) The weld connecting the guide tube to the disc base is approximately one inch in depth and width. No NDE or visual weld inspection is performed on the weld. The importance of the integrity of the weld to valve performance could not be determined.
- 3) The radiographic acceptance criteria was not the same as provided for in the original specification.
It was not evident that the new criteria was evaluated to determine if it was equal to or better than the original requirements.
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- 4) Due to the lack of documentation, the inspectors were unable to verify the welding procedures which were used to manufacture the disc.
These four issues are considered unresolved pending further evaluation (254/84-15-08; 265/84-13-08).
Commonwealth Edison Response to Unresolved Item No. 7 1.
We have similarly been unable to determine the origin of Drawing No. C4063 and suspect that instead of it being a drawing number that it might refer to an old shop order number, quotation number, etc. As previously discussed in this report, drawing DR 34289 should have been included in the description but was inadvertently omitted as a result of a typing error.
This drawing number does exist on the stores inventory code description.
Our investigation also disclosed that this disc has always been a two-piece weldment. The disc base is a carbon steel (A-216 WCB) casting that is radiographically and magnetic particle examined. The disc barrel (guide tube) is carbon steel pipe (A-106 Gr8).
2.
The weld joining the disc base and disc barrel is purely structural in nature and is only required to guide the disc within the valve. As such, no significant forces or moments exist on it and it is not a pressure retaining member. Approximately 15 years of service at our plants have not indicated any distress in this area, tending to confirm Crane's decisions during original manufacture regarding required inspection.
3.
The Crane Co. order acknowledgement for these discs sadresses radiography of the disc per B-102689. We have obtained a copy of B-102689 as approved by General Electric on January 11, 1968, for fabrication. Further, the Crane documentation certifies that the parts were inspected and found to be in accordance with the order requirements. In addition, Crane Co.
confirmed that the Radiographic Inspection Procedure referenced was the same as used during the original fabrication, including revision.
4.
We do not have a copy of Crane's welding procedure for disc fabrication.
However, given the non-pressure boundary application of the weld, its low stress service, and the excellent weldability of the WC8 grade casting and A-106 Gr8 pipe, we have little concern over Crane's apparent use of
" manufacturers" standard process" to assemble the disc. While this may not be typical of the level of quality imposed on a manufacturer of a new component today, we bellese it was considerably more common in the mid to late 60's when these valves were ori.ginally designed and procured.
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