ML20133P233

Forwards Response to Vendor Program Branch Insp Rept 50-344/85-25 on 850809-16.Clarification of Commercial Grade Items Needed to Resolve Differing Interpretations of Regulations

ML20133P233
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/14/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8510310228
Download: ML20133P233 (9)

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October 14, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Re51onal Administrator, Region V U.S. Nuclear Regulatory Commission Creekside Oaks Office Park 1450 Maria Lane, Suite 210 Walnut Creek CA 94596

Dear Mr. Martin:

Inspection Report 50-344/85-025 Vendor Pror. ram Branch Inspection The results of the Vendor Program Branch Inspection of the Trojan Nuclear Plant conducted on August 9-16 were transmitted by NRC Office of Inspection and Enforcement letter dated September 26, 1985. In reviewing this letter and inspection report, we feel a need to provide supplementary information that clarifies our vendor interf ace practices and interpretation of the associated regulatory requirements, and also to provide some additional details on certain specific inspection findings. This information is provided in the attachment.

We are well along with a major updating of our vendor interface programs, as a result of the previous findings in this area by our quality assurance organization and our Nuclear Operations Board, and as a result of the impetus added by the Vendor Program Branch findings. However, we beliove our past practices have been in compliance with a literal interpretation of the regulations of 10 CFR Part 21 and Appendix B to 10 CFR Part 50. Fol-lowing discussions with the Vendor Program Branch, we do understand their current interpretation of the intent of these regulations and how they are being interpreted and enforced elsewhere, even though our procurement and quality programs have been previously approved by the NRC.

A principal reason for differing interpretations of both 10 CFR Part 21, Appendix B to 10 CFR Part 50, and associated ANSI standards (ANSI N18.7 and N45.2.13) involves the appilcation of quality assurance controls to commer-cial grade, or comercially available, off-the-shelf items. This was the major cause for both of the potential violations identified by the Vendor Program Branch at Trojan. We believe that the nuclear industry and the NRC M R 8510310220 051014 2 U

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i N Genier-d MCo T4xv1y Mr. John B. Martin October 14, 1985 Page 2 need to resolve this generic issue in concert, so that it becomes better understood what conunercial grade items are, and what level of quality assurance and associated documentation is required or necessary.

In sununary, while we are connaitted to make immediate improvements in our l vendor interface programs, we do not believe there have been any violations of regulatory requirements. Most importantly, based on our follow-up evaluations and improvements to date, we do not believe that our past pro-curement practices have jeopardized the quality or safety of the operation of Trojan, i Sincerely s

! Bart D. Withers I

Vice President Nuclear I Attachment 1

} c: Mr. Lynn Frank, Director j State of Oregon 1 Department of Energy I

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment License NPF-1 October 14, 1985 Page 1 of 7 PGE RESPONSE AND COMMENTS ON INSPECTION REPORT 50-344/85-025 NRC Item 3b - Procurement PGE's safety-related procurement activities are inadequate in that they fail to meet their commitments to ANSI 45.2.13 and Regulatory Guide 1.123 with respect to verifying the validity of their suppliers' certificates and the effectiveness of their supplier's certification program.

PGE Response The thrust of this finding is that certain cafety-related equipment pur-chased as PGE QA Code D did not have verified suppliers' certificates.

Our procedures, namely NPEP 300-1, allowed the use of QA Code D for pro-curement of off-the-shelf or standard design quality-related equipment when some form of documentation was required, but for which the supplier was not required to have a quality assurance (QA) program. PGE engineer-ins evaluations v. .e performed to e7tablish the requisite requirements and cont ols to be applied to such purenases. This is in compliance with t'o requirements of ANSI N18.7-1976, Section 5.2.13, for commercially off-the-shelf procurements. It is important to note that many of PGE's Code D purchases were for quality-related equipment that was not safety-related.

ANSI 45.2.13-1976 does require tha "means should bn provided to verify the validity of supplier certificates and t'io effectiveness of the certi-fication system, such as during the rerformance of audite of the supplier or independent inspection or test of the items. Such verifications should be conducted by the purchaser at intervals commensurate with the supplier's past quality performance." This requirement is subject to varied inter-pretation. Evaluation and approval of Code D purchases by both Engineering and QA personnel provided reasonable assurance of past qua1Lty performance by the selected supplier. Certification of testing by independent labora-tories, together with PGE's receipt inspection and any preinstallation checks and tests, further served to verify certification.

Five Nuclear Division Procedures (NDPs) have been drafted to strengthen the Nuclear Division procurement program. We are qualifying current Code D vendors via available industry registers, engineering evaluation records, available Plant testing and/or performance records or audits of the supplier to verify certifications. Purchase orders for the last year by the Nuclear Plant Engineering Department (NPED) and for the last six months by the Plant have been reviewed. To date, only 11 vendors who supplied equipment or services under code D purchase orders h.ve been identified that are not qualified by being listed in the CASE register, Bechtel's qualified supplier list, or the ASME vendor " white book". These 11 were either services or products supplied through a distributor. Two

Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment License NPF-1 October 14, 1985 Page 2 of 7 of the 11 have been qualified based on the engineering evaluation per-formed; two were for engineering services that have been evaluated as not safety-related, and one was for a Plant service performed to our proce-dures (and therefore only our QA program applied). The remaining six suppliers will be qualified by one of the above methods. We are confident that they can be qualified based on our efforts to date.

NRC Item 3e - Procurement The thrust of this potential violation of 10 CFR Appendix B is that PGE improperly procured Pafety-related components from two vendors by not

verifying that the t;ndors had effective QA programs and by not imposing any specific quality requirements on the vendors in the purchase orders.

PCE Response Neither of the two examples cited for this item are safety-related, por 10 CFR 50, Appendix B, since neither component prevents or mitigates the consequences of postulated accidents that could cause undue risk to the health and safety of the public. (See Introduction to Appendix B.) The auxiliary feedwater square root extractor feeds a control room flow indi-cator; the RCS pressure recorder is also for control room indication, l

! Neither of these components is utilized as an active part of the Roactor protection or Engineered Safety Features Actuation Systems. Accordingly, neither of these two examples support a finding related to noncompilance with 10 CFR 50, Appendix B, since this regulation does not apply.

While safety-related components have been purchased under similar pCE QA l Code D purchase orders, it is our position that a graded level of QA, per General Design Criterion 1 of Appendix A to 10 CFR 50, has been applied to i such components through the requirements of pGE's own QA program and implementing procedures for design, procurement, documentation, receipt, i testing, and installation, even though specific QA requirements and/or 10 CFR 50, Appendix B, itself may not have been imposed on the vendor.

1 The Nuclear Division procurement program requires safety-related items i purchased to a specific Trojan specification or unique to Trojan, be l bought from a vendor with a QA program. Items that were commercini, such as relays, breakers, solenoid valves, recorders, switches, etc that had been qualified by the manufacturer for the nucioar industry were bought Code D. We did not believe that Appendix B was required to be applied by pCE on the vendors of these commercial items. The qualification by the manufacturer to a nuclear standard of one of his catalog items, in of

itself, did not make it unique to the nuclear industry; further, refer-encing of certain nucioar standards (eg, IERE 323) in purchase documents was considered in some cases to implicitly require application of a QA program by the vendor. Therefore, Appendix B requirements were not applicabic to those commercial purchases.

ls Trojan Nuclear Plant Mr. John B. Martin ,

! Docket 50-344 Attachment i

License NPF-1 October 14, 1985 ,

Page 3 of 7 3

Although there was no objective evidence in the Nuclear Quality Assurance i Department's (NQAD) files that vendors supplying Code D safety-related I materials were qualified vendors, there was evidence in the NPED files

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that an appropriate quality evaluation was performed prior to purchasing these items. NQAD does review and sign-off on all quality-related pur-chase orders including those items in Table 1.

l NRC Item 4 - 10 CFR Part 21 l The thrust of this NRC-identified potential violation of the requirements f

of 10 CFR Part 21 is that PCE did not impose any specific QA or Part 21 i requirements on a vendor that supplied breaker trip units, and that PCE's

} procedures are deficient since they did not require a Part 21 evaluation i for a malfunction that occurred when the trip uni's were tested.

PCE Response I

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The subject breaker trip units were purchased as a standard design off-the-shelf item in accordance with Procedure NPEP 300-1, using a PCE

QA Code D purchase requisition. The trip units were being provided as an

Appendix R fire protection backfit to provide added breaker coordination j protection of a safety-related bus from a nonsafety-related associated

lighting circuit in which the breakers were provided. ,

A l While the trip units were identified on the PCE purchase order to be .

! Class 1E and to meet seismic requiroments, they are considered to be I j commercial grade components. The trip units were only labeled as

] Class 1E for vendor identification purposes - they were not to be utilized i

for a Class 1E application at Trojan. The devices were ordered from a 4

catalog and are in general industrial use. The devices supplied to Trojan are no different than those supplied to other industrial users. Per Sec- i tion 21.3 (al) of 10 CFR 21, since neither the manufacturer's design nor specification of these trip units is unique to NRC-licensed facilities, i they are clearly a commercial grade item, and are not subject to 10 CFR i

Part 21 evaluation and reporting requirements until af ter dedication.

Further, a determination was performed and documented per Section 21.31 of j Part 21, that 10 CFR 21 did not apply. ,

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The engineer for this modification specified in the Detailed Construction Package that the trip units be tested prior to installation. D" ring this test, the units failed and were returned to the vendor, who PCE informed i by telephone. Since the trip units had not yet been designated for use,

! they were therefore not yet dedicated, per Section 21.3 (a4) and (c1) of j Part 21. Accordingly, by both Part 21 and PCE's Part 21 procedure i (NDP 100-4), no Part 21 evaluation nor report was mandated.

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{ Even if the breaker trip units were considered to be basic components, the j deviation which caused them to fall would not have resulted in a defect  !

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment License NPF-1 October 14, 1985 Page 4 of 7 per Section 21.3 (d2), since they had not yet been installed or placed into use or operation. However, to comply with what the Vendor Program Branch considers to be the intent of Part 21, we have immediately processed a change to our Part 21 procedure to clarify when evaluation and reporting is required for basic components.

NRC Item 5 - Control of Nonconformina Material The thrust of the unresolved item in this area is that several mechanical snubbers which had failed testing were found without QC hold tags. There was also a question about the appropriate use of Maintenance Requests (MRs) and Nonconformance Reports (NCRs).

PGE Response The failed snubbers should have either been tagged with QC hold tags or should have been immediately returned to the vendor (which they now have been). Procedure NDP 600-1 is being revised to clarify the appropriate use and evaluations for NCRs and MRs.

NRC Item 6 - Emergency Diesel Generator (EDG) Maintenance

a. Valve Line-Up Verification A discrepancy was noted that none of the EDC cooling system valves were marked or tagged with the appropriate designator, making identification of the valves difficult.

PCE Response The subject valves do not require special marking or tagging. However, we will review the human factors aspect of this further to improve opera-tional identification if needed.

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b. Maintenance l

The thrust of this finding is that PGE has failed to maintain an effective interface with the EDG supplier and that the EDG preventive maintenance program at Trojan is out of date.

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment License NPF-1 October 14, 1935 Page 5 of 7 PGE Response PGE has maintained close contact with Power Systems Division (PSD) of Morrison Knutson concerning preventive maintenance and modifications of the EDGs. This has included regular reviews by PSD of our maintenance program, including onsite reviews by their technical representatives.

Vendor recommendations, including several Power Pointers, that have been received by Trojan have been evaluated and incorporated as appropriate.

Because of our particular EDG service conditions, not all vendor recommen-dations are applicable. Numerous EDG modifications recommended by EMD-GM and provided through PSD have been made, such as turbocharger replacement, soak back lube oil addition, viscous vibration damper installation, etc.

j We will formally request a complete set of past and future vendor recom-i mendations for use in updating our vendor manual for the EDGs.

J j NRC Item 7 - Terry Turbines The thrust of this unresolved item is that PGE accepted and installed equipment which did not conform to the design analyzed in the seismic analysis.

PGE Response The alignment pins have been installed to restore the terry turbine to its original, analyzed seismic level.

j NRC Item 9b - Centrifugal Charging Pump Speed Increasers l

The thrust of this NRC-identified weakness is that PGE failed to perform a timely 10 CFR Part 21 evaluation of a potentially serious common mode failure involving the keyed coupling of the CCP dpeed increaser and pump.

PGE Response j PGE identified the problem using a Part 21 evaluation form (SPI 200-25) on April 1, 1985. In addition, a Maintenance Engineer discussed the keyway condition with the speed increaser vendor during the first week of April.

i A major revision to our Part 21 procedure was issued (Revision 0 to I

NDP 100-4) on April 4, 1985. As a result, the Maintenance Department was

requested to resubmit 10 CFR Part 21 evaluations that were in progress l' using the new forms in NDP 700-4. During discussions regarding this request for resubmittal, it was determined that the problem was not a Part 21 type defect. The problem appeared to be confined to an undersized l key on one CCP only, rather than being generic to the other CCP on the

! diesel-driven AFW pump speed changers. Because of the isolated nature of l the problem, it did not appear to warrant further evaluation under l

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment License NPF-1 October 14, 1985 Page 6 of 7 Part 21. This problem was further discussed between PGE's OERP Coordina-tor and the Maintenance Supervisor in June with the conclusion remaining that Part 21 reporting was not warranted. Because of NRC concern in this inspection, we have initiated a formal Part 21 evaluation.

NRC Item 10 - Post-Modification Testing The thrust of NRC comments in this area is that test documentation was incomplete, missing, or unavailable for several modifications.

PGE Response As part of an evaluation in August of AFW System problems and a special surveillance during the first week of October, the PGE Nuclear Quality Assurance Department addressed four specific concerns expressed in the subject inspection report,

a. RHR System Modification - In every modification reviewed (including RHR System modification), we have determined that documentation existed which demonstrated that appropriate installation checks and tests were performed, even though it may not have been included in the As-Built Packages. However, if testing was performed via an existing POT, PICT, or MP, these testing data were located in the files associated with the POT, PICT, or MP.

b. MSIV Isolation Modification - Both DCP 1 (Electrical) and DCP 2 (Mechanical) were reviewed. It was determined that combinations of portions of three POTS, one PICT, FCN #8 to DCP 1, and a system pressure test were completed that verified proper operation.

c. AFW Flow Control Modification - TPT-137 was reviewed. This Plant test extensively tested the control aspects of the AFW flow control valves including the high flow condition valve closure function. Addition-ally, it was determined that as part of the I&C flow instrumentation calibration procedure, the high flow valve closure function is veri-fled. (It should be noted that POT and PICT data sheets are located separately in their chronological files. However, the above data for the MSIVs and AFW modifications were available at the time of the inspection.)

d. Control of Testing - Inconsistencies associated with the identifica-tion of testing requirements for modifications were identified in PGE's August 1985 QA evaluation of AFW System problems. The process has been reviewed. Action is being taken to clearly identify responsibility and provide additional guidance in preparing and reviewing modification packages.

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment License NPF-1 October 14, 1985 Page 7 of 7

e. Verification of C of C Data No specific examples are provided to support a conclusion that func-tional tests do not verify the validity of the vendor's certification systems. Such tests most frequently do serve to verify that newly installed components perform their intended function as described or inferred by the procurement documents and any vendor certifica+ , to this effect.

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