ML20128F348

Summary of 920113 Meeting W/Util Re Commercial Grade Dedication at Plant

ML20128F348
Person / Time
Site:	San Onofre
Issue date:	02/02/1993
From:	Norrholm L Office of Nuclear Reactor Regulation
To:	Rossi C Office of Nuclear Reactor Regulation
References
GL-91-05, GL-91-5, NUDOCS 9302110359
Download: ML20128F348 (13)

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UNITED STATES 8' 'n NUCLEAR REGULATORY COMMISSION i i I WA$m0 TON, D. C. 20$$$ h

% ,, FEB 0 01993 MEMORANDUM FOR: Charles E. Ros.si, Director Division of Reactor Inspection and Licensee Performance 7

FROM: Leif J. Norrholm, Chief

' Vendor Inspection Branch Division of Reactor inspection o and Licensee Performance

SUBJECT:

MINUTES OF PUBLIC MEETING WITH SOUTHERN CAllf0RNIA EDISON ON COMMERCIAL GRADE DEDICATION AT SAN ON0FRE NUCLEAR GENERATING r STATION Backaround _

Between December 1991 and June 1992, the NRC completed five pilot inspections that were conducted to evaluate the implementation of licensee programs for the procurement and dedication of commercial grade items (CGis) and to' finalize an inspection procedure for future inspections of this type. These~

inspections identified weaknesses in licensee CGI dedication programs and their implementation. During this same period, the NRC received significant-  :

feedback from several utilities and the Nuclear Management and Resources

-Council (NUMARC) questioning the-regulatory basis for the CGI dedication ,

guidance contained in NRC Generic Letter (GL)' 91-05, as well as specific interpretations of that guidance by the NRC inspection teams. Because of the' ,

need for additional discussion of the requirements- and implementing guidance for dedication of CGIs, no enforcement action was taken based on any of the five pilot inspections. Rather, it was decided that a series of meetings with licensees and industry representatives would be beneficial to identify, and attempt to resolve, specific areas of difference. This meeting with-Southern California Edisondur licensees inspected (SCE)ing the pilot inspections. representatives is the secoj '

hetina Summary On January 13, 1992, the Director, Division of Reactor inspection:and Licensee ,

Performance,:and members of the Vendor Inspection Branch met with Harold B._ -

Ray, Senior Vice President,-Nuclear, and other re)resentatives of SCE attthe San Onofre Nuclear Generating Station-(SONGS). Tae meeting provided an-opportunity to discuss key procurement- and commercial grade dedicatioi. issues identified during the~five pilot inspections for which the NRC'and SCE might have differing. views, and to discuss certain' dedication packages that were=

identified as containing deficiencies during the NRC's December 199) .

procurement inspection at SONGS. The meeting agenda is included as1 Enclosure p 1._ The NRC stated that the objective of the meeting was to obtain input- for the NRC.to aid in its effort to identify the ) roper level of dedication necessary to assure safety and compliance wit 1 10 CFR 50,-Appendix B. '

9302110359 930202' DR 090030

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Charles E. Rossi In order to facilitate the discussion, the NRC provided SCE a list of generic dedicationissues(Enclosure public ineeting held with the NF.2)ConNovemberthat was originally 13, 1992. These dedication provided to NUMARC in a istues were also used as discussion points for the meetings with Florida Power Corporation on December 4, 1992, and with NUMARC on December 10, 1992. The rnain dedication issues include the basis for the selection and verification of critical characteristics, sampling, traceability, commercial grade surveys, like-for-like re)lacements, and acceptance of vendor /su) plier iiocumentation and are tied eitler directly or indirectly to Appendix 3 requirements for safety-related applications. These issues were derived from previcus meetings with NUMARC and represent the major points of ongoing discussion.

During the opening remarks, SCE reiterated their previous position that they take issue with the NRC statements in the cover letter to inspection Re) ort 91-201, that there was an apparent two year delay by SCE in upgrading t1eir procurement and commercial grade dedication program to be in accordance with NUMARC's first procurement in .iative. SCE also stated that no significant disagreements exist between the SCE and NRC positions regarding what is necessary to comply with the requirements of 10 CFR S0, Appendix B for commercially dedicated items. However, SCE did identify some areas, including sampling, traceability, and like-for-like replacements, where they felt additional clarification would more precisely identify the staff's expectations. The following are the generic dedication issues where SCE felt additional clarification may be appropriate.

1. BASIS FOR THE SELECTION AND VERIFICATION OF CRITICAL CHARACTERISTICS

a. Consideration of the item's Safety function SCE did not take issue with the need to relate critical characteristics to the items safety function. However, SCE stated that original plant equipment manufactured under Appendix B quality assurance (QA) programs most likely did not receive the same high level of quality assurance or compensatory measures that SCE is now performing when dedicating CGls to meet GL-91-OS guidelines. They stated that the NRC position that the dedication process-should result in a CGI with the same performance reliability as a like item manufactured under an Appendix B program may, therefore, be somewhat confusing,

b. Failure Modes and Eftects Analysis SCE stated that the last sentence could be interpreted as requiring licensees to go beyond the original design basis for CGis by making failure modes analysis mandatory.

3 Charles E. Rossi 2. SAMPLING

b. hiablishment of Let/ Batch Control SCE stated they use statistical sampling plans for items for which they have not established lot / batch control as long as they adjust the sampling plan for testing accordingly, lhey are establishing a confidence level that they feel is acceptable for the given situation. SCE stated they are using Electronics Industries Association Standards along with the EpR1 guideline (NClG-19) for sampling plans for CGI acceptance.

c. Bulk Commodity items SCE suggested that this section be retitled from bulk commodity items to all items for which lot / batch control has not been established.

3. TRACEABILITY

a. Material / Items purchased from Distributors SCE suggested deletion of the second sentence in the aaragraph concerning the necessity of traceability to prevent tie use of incorrect or defective material.

4. LIKE-FOR-LIKE REPLACEMENTS

a. Egpl nement with an Identical item SCE stated that the identical item definition is confusing and recommended that it be removed. They also suggested that it might be appropriate to consider the items form, fit, and function as-part of the like-for-like verification evaluation.

Following the discussion on the dedication issues, SCE summarized their corrective actions for the specific dedication packages that were identified as containing deficiencies in the 1991 NRC inspection report (Enclosure 3).

They discussed their actions in response to the specific findings and then used sample dedication packages to demonstrate the current status of the SONGS-commercial grade dedication program. Based on the summary of SCE actions in response to the specific findings identified in the inspection report, it appears that these issues have been satisfactorily resolved, finally. it was stated that the NRC would be conducting a-public workshop which will address issues concerning the existing dedication guidance and specific interpretations of that guidance. Prior to the public workshop, the

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Charles E. Rossi -f proposed inspection procedure for future inspections will be issued for public t:omment and discussion at the workshop. A list of meeting attendees is included as Enclosure 4.

The Vendor Inspection Branch is considering all the comments provided by SCE.

1he meeting provided a useful exchange of information and accomplished the goal of aiding the NRC by gaining industry insight and feedback related to the commercial grade dedication process, id Leif J. Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance '

Office of Nuclear Reactor Regulation

Enclosures:

1. Metting Purpose and Agenda

2. Dedication Issues for Discussion

3. Summary of NRC Findings and SCE Actions

4. Meeting Attendance List cc w/o enclosures:

W. Russell DISTRIBUTION:

VlB R/F w/ enclosures DRIL R/F w/ enclosures AMendiola w/o enclosures GZech w/o enclosures RPettis w/ enclosures GCwalina w/ enclosures HWong, RV, w/ enclosures TQuay, NRR, w/o enclosures Mfields NRR, w/o enclosures PDR/ Central files w/ enclosures

• See Previous Concurrence OfflCE VIB:DRil VIB:DRIL C:VIB:DRIL DD:DRll D:DRIL l

NAME RHeintyre* UPotapovs* LNorrholm*

MW RZimmerman C's (R %/e/

CERossi "'

DATE 1/29/93 1/29/93 1/29/93- 2 /;t/93 2 / c/93 NO NO NO NO .NO-0FFICIAL RECORD COPY DOC: P:\SCE-MTG. MIN I

Enctosure t MEETING ON COMMERCIAL @RADE DEDICATION ISSUES JANUARY 13,1993 PURPOSE To discuss Southern California Edison's programs for the procurement and dedication of commercial grado items for use in safety related applications at San Onofre Nuclear Generating Station, Units 2 and 3.

AGENDA

1. NRC presentation / views on Commercial Grade Dedication issues:

BASIS FOR THE SELECTION AND VERIFICATION OF CRITICAL CHARACTERISTICS Consideration of items's Safety Function.

Failure Modes and Effects Analysis.

Reasonable Assurance Engineering Judgement SAMPLING Established Heat Traceability (materials).

Established Lot / Batch Control.

Bulk Commodity items.

TRACEABILITY Material / Items Purchased from Distributors.

LIKE FOR LIKE REPLACEMENTS Replacement with identicalitem.

Like for Like Verification.

ACCEPTANCE OF CMTR AND CERTIFICATES OF COMPLIANCE Validity Verified through Vendor / Supplier Audit or Testing. .

2. SCE comments on NRC Dedication issues.

3. SCE presentation on changes to SCE's commercial grade dedication program since the December 1991 inspection.

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, T.nclosure 3 NRC MEETING WITH SOUTHERN cal.IFORNIA EDISON JARJARY 13, 1993 DEDICATION !$5U05 FOR DISCUS $10N

1. BASIS FOR THE SELECTION AND VERIFICATION OF CRITICAL. CHARACTERISTICS

a. Consideration of item's Safety function Critical characteristics should be based on the item's safety function. The licensee is responsible for identifying the important design, materici, and performance characteristics for each item, establishing acceptance criteria for these characteristics, and providing reasonable assurance of conformance to these criteria.

Upon the completion of the dedication process, the quality assurance or compensatory measures applied to those aspects of the item which directly affect its safety function should result in the same level performance reliability as for a like item manufactured ender an e Appendix B program,

b. D ilure Modes and Effects Analysis f ailure modes and effects analysis can be a valuable tool which can be used for both, classification of an item as safety-related or nonsafety-related and for identifying the critical characteristics of an item. An evaluation of credible failure modes of an item in its operating environment and the effect of these failure modes on the item's safety function should be used as the basis for selection of critical attributes to be verified during the dedicatic,n process,

c. Reasonable Assurance The dedication process is not substitute for Appendix B. Rather, it represents a method of achieving compliance with Appendix B, with the purchaser assuming many of the responsibilities for assuring quality and functionality of an item which had previously been the responsibility of the vendor. In this context, reasonable assurance consists of the purchaser providing control over the activities af fecting the item's quality to an extent consistent with the item's importance to safety. For more complex items, dialogue with the original equipment manufacturer may be necessary to identify the design and functional parameters of specific piece parts.

d. Enoineerino Judaement The use of engineering judgement in the dedication process is acceptable providing that the bases for such judgements are documented.

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. SAMPLING

a. [itablished Heat Traceability (materials)

When heat traceability of material is established through a commercial grade survey, the party performing dedication of this material may accept the certified material test report (CMTR) that certifies activities which must be performed during (1) the melting, and (2) the heat analysis; provided that the party dedicating the material performs or subcontracts the performance of all other requirements of the material specification and/or those requirements identified as critical characteristics, on a representative sample of that material.

b. Established Lot / Batch Control When Lot / Batch (defined as units of product of a single type, grade, class, size and composition, manufactured under essentially the same conditions, and at essentially the same time) control is established through a commercial grade survey, the party performing dedication can develop sampling plans based on star.dard statistical methods.

Such sample plans should be documented and provide for the verification of the critical characteristics with confidence level consistent with the item's importance to safety,

c. Bulk Commodity Items When Lot / Batch traceability can not be established, each item may need to be 1:sted. Any sampling plans for such items would need to be considered on individual, item-specific basis and assure that they are capable e'fmwiding a high-level of assurance of the item's suitabili *+0c iervice.

3. TRACEABILITY

a. Baterial/ Items Purchased from Distributors Traceability can be defined as the ability to verify the history, location, or application of an item by means of reenrded identification (NQA ). Traceability is necessary to prevent the use of incorrect or defective material and should be maintained throughout the dedication process. Where the item's acceptance is based entirely or partially on a certification by the manufacturer, the traceability must extend to the manufacturer.- If intermediaries (distributors) are included in the supply chain, their capability of l maintaining traceability should be assured by audit.

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4. COMMERCIAL GRADE SURVEYS

a. Verification of Vendor's Control of SDttific Characteristics A commercial grade survey should be specific to the scope of the commercial grade item or items being purchased. The vendor's controls of specific critical charar.tc ls to be vcrified during the survey should be identified in th. wr ey plan. The verification should be accomplished by reviewing the vendor's program / procedures controlling these characteristics and observing the actual implementation of these controls in the manufacture of items identical or similar to the items being purchased.

b. Identification of Aeolicable Proaram/P Ig gdures The vendor must have documented program and/or procedures to control the critical characteristics of the item or items being procured which are to be verified during the survey. When many items are being purchased, a survey of a representative group of similar items may be sufficient to demonstrate that adequate controls exists. If the vendor's controls are determined to be satisfactory, purchase orders for these items should invoke these controls as contract requirements by referencing the applicable program / procedure and revision. Upon completion of the work, the vendor should certify compliance with the purchase requirements. ,

kr.. mentation of Survey results

, annercial grade survey documentation sheuld include the iaentification of item or items for which the vendor is being surveyed, identification of the critical characteristics of these items which the vendor is expected to control, identification of the controls to be applied (program / procedure and revision) and a description of the verification activities performed and results obtained. Deficiencies identified during the survey which may affect control of the identified critical characteristics should be addressed by requiring the vendor to institute additional controls or by utilizing other verification and acceptance methods.

5. LIKE-FOR-LIKE REPLACEMENTS

a. Replacement with Identical item If it can be demonstrated that the replacement item is identical to the item that it replaces, review of the replacement item's safety functions and identification of the critical characteristics are not necessary. An example of such replacement would be the replacement of an installed commercial grade item with an item from warehouse which has the same model/part number and which was purchased from the same vendor at the same time.

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=b. Like-for-like Verification- >

If it can not.be demonstrated that the replacement"itemiis identical or. if differences between the items are identified, an evaluation is-  :

neces'sary-to determine:if'any changes ain design.: material.c or< af manufacturing process could impact:the item's, critical 3 characteristics-and'its ability to perform-the. intended safety

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6. ACCEPTANCEOFCERTIFIEDMATERIALTESTREPORTS(CMTRs)ANDCERTIFICATESOF -

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COMPLIANCE (C0Cs)

a. Validity Verified Throuch-Vendor /Sunolier' Audit or Testinos The validity of vendor CMTR: and COCs1should be verified J1This!can: ,

, be accomplished through a commercial- grade survey or,-for simpleL Li items, periodic testing of-the product upon receipt.. Such _ .

verifications should be conducted at intervals commensurate:with the vendor's past oerformance.- -If the item's supply'cbain includes- a- .

distributor, tie verification survey should include _ warehousing-  !

and/or traceability controls at the distributor's' facility.--

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na Enclosure 3. .1

SUMMARY

OF NRC (91-2011 FINDINGS AND SCE ACTIONS ' b MDP-04'; Pump Shaft j

Description:

The safety' function of monel pumpishaft for Unit-11 ~

Safety Injection Pumps was not1 identified;and no: '

gaidance given on-the PEP for: verifying-materials.-

9 Action: This part is- unique to-Unit li(Unit 1 permanently-removed from service 12/01/92). The review-date and PEP have been removed from the_ material-code, preventing, reorder without Procurement Engineering review and theu PEP has been cancelled. If an order'was_ required, a technical evaluation ar.d new PEP would--be-issued.

MDP-08; Impoller .

Descripton: The safety function of pump-impeller for' Unit 1LSpare. S Spent Fuel Cooling Pump was not-identified and the material-was not tested during the initial receiptJ inspection. The material has since been tented and-found to be acceptable. ,

Action: See Action listed for Item (1). .

MDP-10; Valve Stem and Plue

Description:

The safety function and seismic qualification of:

control valve stem and plug assembly.foruUnit 1 TDAFW . 3 Pump Steam Supply Regulating Valve were not identified ~

and the source' inspection for the reviewLof materiali control and documenting of the dimensional. inspection was inadquate.

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Action: See Action listed for Item'(1). ,

MDP-24; Chevron Motor oil

Description:

critical. characteristics'for-Delo 6170 Motor oil were -

not identifed or verified'to; meet-the. safety function.

Action: To control the procurement of any oils after 1\1\93,:

the review date has been removed from.all applicable material codes preventing' reorder lwithout Procurement;

• Engineering review. A draft-technical evaluation 1(TE-SMN0006) has been written' identifying safetyffunction-as " Reduce friction in equipmentLthat has. metal?to metal contact" and critical characteristics:as:

" manufacturer's_part-number,ibatch number,-product" purity, kinematic viscos'ity, and manufacturer'si additive package". An-interim-PEP 1(V178 and-later, SMN0006) was issued to dedicate all-oils received by>

verification of the critical characteristics identified in TE-SMN0004 with the exception of-the additive package. Due to the specific naturelof:each a'dditive and the complicated method of_ detection, the PEPfwill be revised as information on the additive package and' 4 test methods becomes available.

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4 MDP-23'9 ASCO Soleno'id Valves (Description: No' safety functions were identified and critical ,

characteristics were limited to part number, 't configuration, and operability.

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Actions: PEP V168 Rev 0 was prepared in Sept, 1991 asia' Generic >

PEP to purchase _SOV's. This PEP (Rev 2) Vas cancelled q because all of-the SOV's covered by'the PEP-(except one) were installed in Unit =1, which-has been removao from service. The one Sov for Units 2/3 -isicurrently-purchased P/L II via PEP K258. The need to develop =a P/L V PEP for SOV's has not been identified-at this time.

]lLD_P-1 THRU 9 ; General Electric MCCB's

Description:

The PEPS did not consider all safety functions for:the MCCB's and failed to identify appropriate; critical characteristics for several of the safety functions:

which were identified. The verification methods'and acceptance criteria for several identified critical enaracteristics were not adequately specified.

Actions: PEP 82 Rev 0 was approved in Dec,_1989_to purchase,and accept safety related General Electric MCCB's'in-accordance with the requirements--of_NRC Bulletin'88-10._ .

The PEP (Rev 1) was cancelled in order to develop a new'  ?

PEP which meets the requirements in GL 91-05. Work'has -

not started on the new PEP because new. PEP's-are-currently being developed for:open requisitions in:

other areas.

EDP-10: Texas I_n_struments MCCB's . ,

Description:

The PEP's did not consider.all safetyffunctions-for"the MCCB's and failed to identify appropriate critica11 characteristics for several of the safety functions which were identified. The verification methods and__

acceptance criteria-for several identifiedicritical) .

characteristics were not adequately 1specified; Action: PEP 88 Rev 0 was approved in'Nov, 1989 to purchasefand accept safety'related TI'MCCB's inLaccordance with the:

requirements of NRC Bulletin 88-10.'The PEP'was cancelled in order to develop a new PEP lwhich-meets the.

requirements in GL'91-05. Work hasLnot_startedion-the new PEP because new PEP's are. currently _being; developed:

for open requisitions in other areas.'

EDP-ll; Siemens MCCB's.

Description:

The PEPS did not' consider all safety functions for the MCCBs and failed.to identify appropriate' critical characteristics for several of the. safety functions.

which were' identified. The verification methods-and acceptance criteria for several identifiedicritical-

l. characteristics were not' adequately specified.

L l Action: PEP 96 Rev 0 was approved in Sept,-1989 to purchase and:

l' accept safety related Seimens MCCB's in.accordance with h

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Etho-requirements.of;NRC Bulletinf88-10'.LThslPEP:was. .  !

'. " cancellediin order to develop ainew PEP which meetsethe

-requirements;in:GL 91-05. Work:has not started-on the- ,

-new PEP because new PEP's are? currently ~being developed ~ '

for:open_ requisitions-.in other. areas.:

EDP-181 Sioma-Relavs-(Hanufactured-by MAGNECRAFTt M

Description:

The-

PEP failed to-document consideration cfitheorelay's

-safety function and failed to evaluate'significant <

attributes _such as insulation resistance,. coil and contact voltage ratings, coil and. contact current ratings, contact: timing,:and; seismic capability as  ;

critical. characteristics. i Action: PEP Q667 Rev 0 was approved in March,. 1991 to purchase '

and accept a relay for a particular application. The; PEP was cancelled because-it was developed for a one ;

time purchase. A.new PEP will not be developed unless a requisition-is. issued for'_the!particular item.

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Enclosure 4 SAN ONOFRE NUCLEAR' GENERATING STATION PUBLIC MEETING JANUARY 13,1993 COMMERCIAL GRADE DEDICATION ISSUES ,

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