ML20133G751
| ML20133G751 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/03/1985 |
| From: | Boardman J, Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133G722 | List: |
| References | |
| 50-382-85-04, 50-382-85-4, NUDOCS 8510160109 | |
| Download: ML20133G751 (9) | |
See also: IR 05000382/1985004
Text
APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-382/85-04
Operating License:
Docket:
50-382
Licensee: Louisiana Power and Light Company (LP&L)
142 Delaronde Street
hew Orleans, Louisiana 70174
Facility Name: Waterford Steam Electric Station, Unit 3
Inspection At:
Taft, Louisiana
Inspection Conducted:
Februa ry 11-15, 1985
Inspector:
.
if27k
J h. Boardman, Reactor Inspector, Operations
Dat6
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' ections, Reactor Safety Branch
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Approved-
D$M
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/c/r W
G. L. Constable, Chief, Project Section C
Dat6 '
Reactor Projects Branch
Inspection Summary
Inspection Conducted February 11-15, 1985 (Report 50-382/85-04)
Areas Inspected:
Reactive, unannounced inspection of followup on previously
identified licensee procurement items, including replacement components and
parts for safety-related applications.
The inspection involved
42 inspector-hours onsite by one NRC inspector.
Results: Within the area inspected (Procurement), two violations were ident-
ified in paragraph 2.
Failure of documentation of replacement parts for safety-
related ventilation heaters for charcoal filters to meet quality and design
certification requirements, and failure to have procedures:
(1) for verification
of supplier acceptance of design and quality changes, (2) review of spare parts
against EBASCO as-built specifications, (3) design change review of purchase
order major exceptions, (4) and maintenance of equipment qualification.
85101 % $ $
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
K. Simister, Commercial Manager
R. P. Barkhurst, Plant Manager
- T. F. Gerrets, Corporate Quality Assurance (QA) Manager
- J. Woods, Plant QA Manager
- T. Chiles, Material Superintendent
- K. Brewster, On-Site Licensing Engineer
G. Wuller, On-Site Licensing
G. Ingrahan
- P. V. Prasankumar, Technical Support Supervisor
- W. M. Morgan, Vendor QA Manager
F. J. Englebracht, Manager Plant Administrative Services
M. Hamilton, Plant Engineering
- A. S. Lockhart, Consultant
- S. Alleman, Assistant Plant Manager Technical Services
J. J. Zabritski, Plant Quality
R. Naylor, Project Engineering
NRC Personnel
- G. L. Constable, Senior Resident Inspector
- T. Flippo. Resident Inspector
- Denotes those attending the exit interview on February 15, 1985.
The NRC inspector also interviewed other licensee and contractor
personnel.
2.
Review of Licensee Significant Deficiency
(0 pen) SCD-63 Procurement of Spare and Replacement Parts
a.
LP&L Operation Phase Spare, Repair, and Replacement Parts for the
Emergency Feed Water (EFW) Pump Motors.
(1)
(Closed) Unresolved Item (8501-02) - Lack of licensee procedure
to verify supplier acceptance of and compliance with purchase
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order changes for safety-related parts, components or material
which affect quality (Unresolved).
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During this inspection the NRC inspector determined that the
licensee had no procedures to verify supplier acceptance of, and
compliance with, purchase order changes not substantiated by
Certified Material Test Reports (CMTRs) and other such cases
where specific required data can be verified.
This fact was determined by review of licensee purchase order
(P0) L222580. As discussed in NRC Inspection Report 50-382/8501,
Bingham-Williamette personnel said that they had no documentation
of receipt of Supplement 3 to the subject order. Licensee
procedures do not require verification and documentation of
vendor acceptance of P0 changes, nor does the licensee require
certificates of conformance, or compliance to identify the
revision of the purchase order, when P0 changes modify safety-
related design or quality requirements.
Procedures and documentation available to the NRC inspector show
that the P0 revision to which the parts were applied was not
verified by either the licensee or Burns and Roe (B&R) during
review of SCD-63.
Licensee personnel indicated that they would revise existing
procedures to incorporate these controls for future procurement
but not for previously procurred parts. See paragraph 2.f for
the disposition of this finding.
(2) Lack of Design Review for LP&L Major Exception Forms
By Major Exception form dated November 28, 1983, LP&L made all
items on P0 No. L22258D " commercial grade," including the motor
core (stator) which was covered by equipment qualification (EQ)
to NUREG 0588. This major exception was not reviewed or signed
by the LP&L EQ coordinator, nor did it have a design review,
including a 10 CFR 50.59 review, by either plant eng).ieering or
LP&L project engineering. This Major Exception form was
processed after the completion of the B&R review of spare parts.
LP&L project engineering told the NRC inspector that the motor
core could not be accepted unless an acceptable analysis could
be performed on its insulation system for compliance with its EQ
requirements. The motor core had not been accepted, but it could
have been accepted based on LP&L procedures and the requirement
of the purchase order'at the time this item was identified by
the NRC inspector.
See paragraph 2.f for disposition of this
finding.
At the time of this inspection LP&L procedures did not require'
review of Major Exception forms for design changes, including
the deletion of EQ requirements and performance of a review in
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accordance with 10 CFR 50.59, as necessary to meet the require-
ments of 10 CFR 50, Appendix B, Criterion III. Criterion III
states that design changes, including field changes, shall be
subject to design control measures commensurate with those
applied to the original design and be approved by the organiza-
tion that performed the original design unless the applicant
designates another responsible organization. See paragragh 2.f
for the disposition of this finding.
b.
Procurement of Phase Safety-Related Components and Parts for
Ventilation Systems Filter Heaters
(1) Deletion of Original Design Requirements for Replacement Parts
LP&L PR 51313, P0 L260980, specified safety-related parts to the
requirements of the original equipment ordered by EBASCO on P0
No. NY 403553, Supplements 0-8, and EBASCO specification LOU
1564.748D, Revision 10.
LP&L Major Exception form dated September 27, 1982, removed the
original EBASCO requirements for these components and parts and
made them nonsafety-related, no QA required.
(It also deleted
P0 items 16-22.) This deletion of EBASCO requirements was not
approved by LP&L plant engineering or LP&L project engineering,
or another organization authorized to review design changes, as
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discussed in paragraph 2.a(2).
(2) Original EBASCO Safety-Related Ventilation Heating System
did not meet Certification and Quality Assurance Requirements
The reason for the Major Exception form, dated September 27,
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1982, was a letter from the safety-related ventilation heater
system manufacturer stating that the LP&L P0, which duplicated
the requirements of the original EBASCO P0, " required
certification and quality assurance program requirements which
are considerably beyond those under which the original electric
heating coils were manufactured.
If it is mandatory that these
requirements be met as stated in the requests, we will be unable
to offer a quotation of these replacement parts." This letter
categorically stated that INDEECO could not, and had not met the
EBASCO requirements.
The NRC inspector reviewed available site documentation to
determine EBASCO QA approval of this manufacturer. EBASCO
documentation identified to the NRC inspector on site during the
inspection and by telephone from LP&L on February 25, 1985,
shows only the following:
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(a) September 23, 1976, an EBASCO letter accepted the proposed
Industrial Engineering and Equipment Co. (INDEECO) QA
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program corrective action.
(b) August 1978 disapproval by EBASCO of INDEECO's QA Manual .
(c) September 1978 disapproval of INDEEC0's revised QA Manual
by EBASCO.
(d) October 1982 approval of INDEECO by EBASCO.
A review of material receipts for INDEECO on P0 No. NY 403556
shows most material apparently was received between 1977 and
1979 with two receipts in December 1982. As a result,
essentially all actions performed by INDEECO were performed
using a QA program which had not been approved by EBASCO. Al so ,
as stated in the beginning of paragraph 2.b.(2), INDEEC0
documented that they never met involved requirements.
10 CFR 50, Appendix B, Criterion VII requires control of
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purchased material and that the effectiveness of the control of
quality by contractors be periodically assessed.
Safety-related components supplied by INDEECO are seismic
Category 1.
Waterford 3 Steam Electric Station FSAR, Table 3.2-1, Note 13,
states that all structures, systems and components identified as
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seismic Category 1 receive the full 10 CFR 50, Appendix B
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quality assurance program.
Documentation does not support that LP&L met 10 CFR 50,
Appendix B, Criterion VII, with regard to assurance of the
acceptability of INDEEC0's compliance with Waterford 3 design
base procurement requirements for safety-related ventilation
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heaters and associated components, and replacement parts, used
with charcoal filters. This failure is an apparent violation of
10 CFR 50, Appendix B, Criterion VII (50-382/8504-01).
c.
LP&L Accertance of Spare and Repair Parts Without Design Control
On Spare Parts Equivalency Evaluation Report (SPEER)85-159, dated
February 11, 1985, LP&L plant engineering performed a technical
review of a shield butiding ventilation EHC power switch ordered as
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ncnsafety-related, commercial grade on LP&L P0 L260980. This switch
was classified on the SPEER as Class 1E, seismic, harsh environment.
The component was accepted. The NRC inspector asked the plant
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engineer who prepared the SPEER if his review included verification
that the switch met the requirements of the latest revisions of the
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EBASCO specification and the original EBASCO P0 (see paragraph 2.b
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above). The LP&L engineer stated that he had not.
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The NRC inspector had determined that Revision 12, dated August 17,
1984, was the latest revision of EBASCO specification 1564.7480, and
that Supplement 12 dated November 15, 1984, was the latest to EBASCO
P0 NY 403558. The NRC inspector could find no procedure to require,
or document, that previously purchased operation phase spare
components and parts be reviewed prior to use for design control
relative to changes in EBASCO specifications, to assure that
replacements for safety-related applications meet the latest design
requirements. Such a lack of procedures was covered in NRC Inspection
Report 50-382/84-42, violation (8442-01) but this specific exan.ple
was not in the licensee response to the violation. See paragraph 2.f
for disposition of this finding.
d.
Recent EBASCO Changes to Purchase Orders for Which all Material had
been Delivered and Apparent Failure to Invoke 10 CFR 21 on Suppliers
In conjunction with review of LP&L P0 L-26098-D and L-22258-D,
discussed in Sections 2a, 2b, and 2d above, the NRC inspector
reviewed the original EBASCO purchase P0s for the involved material,
NY 403556 and NY 403431, respectively.
Both of these EBASCO orders had relatively recent changes, as did the
applicable EBASCO design specifications. The changes post-dated
delivery of the components.
As reviewed in the LP&L project records files, EBASCO P0 HY 403431
contained Supplement 14, issued December 9, 1983, and EBASCO
specification LOU 1564.177R3, dated December 7,1983. There was no
documentation in the LP&L project records that the vendor had
accepted this, or any supplement of the EBASCO order. LP&L project
records were missing Supplements 10 through 12 of the EBASCO order.
For P0 NY 403431, the NRC inspector could find no documentation that
10 CFR 21 was invoked on the vendor.
As reviewed in the LP&L project records files, EBASCO P0 NY 403556
contained Supplement 12 dated November 5,1984, and specification
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LOU 1564.7480, Revision 12, dated August 17, 1984
No documentation
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in LP&L project records showed acceptance by the vendor of any PO
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Supplement, and Supplements 4 through 8 were not in LPAL project
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records.
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The issuance of P0 supplements transmitting revised design speciff-
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cations after material delivery, the lack of completeness of LP&L
project records files, and the apparent failure to invoke 10 CFR 21
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on manufacturers, such as the manufacturer of the seismic Category 1
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safety-related system for charcoal filter heaters (see paragraph 2.b(2)
for the apparent deficiencies of this vendor) will remain an unresolved
item (50-382/8504-02) pending further review by the NRC inspector
during a subsequent inspection.
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e.
Apparent Problems Related to the LP&L Procedure Governing Procurement
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of Safety-Related Replacement Components and Parts Requiring
Equipment Qualification (EQ)
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As part of the evaluation of SCD-63, the NRC inspector began a review
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of the licensee procedure for procurement of EQ replacement
components and parts.
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LP&L plant engineering identified to the NRC inspector Administrative
Procedure PE-2-014, Equipment Qualification, Revision 1, dated
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January 15, 1984, as being applicable for procurement of replacement
components and parts for EQ applications.
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PE-2-014 Revision 0, was approved September 29, 1982. Prior to that
time there was no LP&L procedure controlling EQ or the procurement of
replacement components and parts for EQ applications.
From 1978, when LP&L initiated procurement of operations phase
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replacement, components and spare parts, until 1982 when PE-2-014,
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Revision 0, was issued, there was no procedure or EQ coordinator to
prevent the ordering, acceptance, and installation of unqualified
components and parts for EQ applications. There is no identified
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procedure or documentation that this factor was considered by either
LP&L or B&R during their review of SCD-63.
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LP&L personnel identified procedure PE-2-014 as being the applicable
procedure governing EQ replacement parts and components during the
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exit interview on February 15, 1985, and after the exit interview,
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gave him a copy of the current procedure.
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Subsequently, the NRC inspector reviewed the procedure, identifying
the following problems which were identified to LP&L:
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(1) Reference 2.20.3 is LP&L procedure UNT-8-002, " Processing of
Station Procurement Documents." UNT-8-002 is referenced in
Section 5.7 but was cancelled January 28, 1984.
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(2) Section 3.12 states like-for-like - Description of replacement
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of an item with an exact duplicate. The replacement must be by
the same manufacturer and be the same model and design.
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Section 5.4.1.1 states that, for a previous qualification to
remain valid, design of the item and its production controls
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have not been changed. Section 5.4.1.3 states that adequate
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documentary proof of 5.4.1.1 must be furnished.
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As discussed in this report, LP&L has ordered replacement parts
for EQ applications as commercial grade without verification or
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documentation that they are the same design as the part
originally qualified, or under the same production controls.
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(3) Section 4.2.1.2, Engineering and Technical Services Group (ETS)
shall ensure that all required vendor documentation is
furnished. This requirement interfaces with Section 4.6 which
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requires the nonexistent procurement task force coordinator
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(EQC) to review safety-related purchase and receiving documents.
The LP&L materials management group, which replaced the
procurement task force, was unaware of this requirement, and had
not complied with it. As a result, apparently none of these
sections have been complied with .
(4) Sections 5.4.4, 5.8.1.4, 5.11.4, 5.12.2.2 and 5.12.4.1 refer to
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LP&L procedure UNT-8-001 for qualification requirements and
methods.
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Section 5.8.1.4 references UNT-8-001, Attachment 6.18.
No
approved revision of UNT-8-001 contained an Attachment 6.18, or
qualifico:1on requirements and methods.
(5) Section 5.10 references the presently nonexistent procurement
task force coordinator.
(6) Section 5.10.1 requires generation of records showing proper
storage and maintenance during storage of EQ material, review of
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these records by the EQC and identificatien of the records as
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qualification records. LP&L materials management personnel were
unaware of this requirement of review by the EQC.
Based on these findings, LP&L did not have in-place implenenting
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procedures for maintenance of equipment qualifications, including
their comitment to have such procedure prior to fuel load as
committed in Section A6 of Revision 2 (November 1982) of LP&L's
.
Waterford SES Unit No. 3 Response to NUREG-0588 Revision 2.
See
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paragraph 2.f for disposition of this finding,
f.
Apparent Failure to Comply with 10 CFR 50, Appendix B, for
Procedures Governing Replacement Components and Parts for Safety-
Related Applications and Maintenance of Equipment Qualification
10 CFR 50, Appendix B, Criterion V requires that activities affecting
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quality shall be prescribed by documented procedures. As discussed
above, LP&L failed to have procedures:
(1) To verify vendor acceptance of, and certification of compliance
to, (where applicable) purchase order changes which affect the
design or quality of safety-related equipment parts or material
(paragraph 2a(1)).
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(2) To require design review, including a 10 CFR 50.59 review, of P0
major exceptions (paragraphs 2.a(2).
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(3) To assure the review of previously procured, and to procure
future replacement and spare parts, components, and material to
the final EBASCO "as built" specifications (paragraph 2c).
(4) To assure maintenance of Equipment Qualification as committed
(paragraph 2.e)
Failure to have procedures for activities affecting quality is a
violation of 10 CFR 50, Appendix B, Criterion V (50-382/8504-03).
3.
Unresolved items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations, or
deviations. One unresolved item disclosed during the inspection is
discussed in paragraph 2.
4.
Exit Interview
The NRC inspector met with the licensee representatives (denoted in
paragraph 1) and the NRC resident inspectors at the conclusion of the
inspection on February 15, 1985. The NRC inspector sunmarized the
purpose, scope, and findings of the inspection.
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