ML20137E516

Insp Rept 50-344/85-38 on 851030-31.Potential Enforcement Finding Re safety-related Procurement Substantiated.Open Items 344-85-025-05 & 344-85-025-06 Closed.Major Areas Inspected:Classification of Procurements

ML20137E516
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/03/1986
From:	Baker E, Kirsch D, Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20137E433	List: ML20137E428 ML20137E516
References
50-344-85-38, TAC-60659, NUDOCS 8601170267
Download: ML20137E516 (6)

See also: IR 05000344/1985038

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U. S. NUCLEAR REGULATORY COMMISSION

Report No.: 50-344/85-038

Docket No.: 50-344

Licensee No.: NPF-1

Licensee: Portland General Electric Company

121 S. W. Salmon Street

Portland, Oregon 97204

Facility Name: Trojan

Inspection at: Rainier and Portland, Oregon

Inspection Conducted: October 30-31, 1985

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Inspectors: , CP - 4,r/ / # I

D. F. Kirsch, Deputy DirectoY, Division of Resident, Dat'e

Reactor Projects and Engineering Programs

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E. T. Baker, Reactive Inspection Section ~Dath

Approved by: , 85

G. G. Z(ch,,/

q Chief, Vendor Program Branch Date

8601170267 860115

PDR ADOCM 05000344

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SUMERY:

Inspection during the period October 30-31,-1985 (Report No. 50-344/85-038)

. Areas Inspected: One inspector from the Vendor Program Branch, Office of

Inspection and Enforcement and one inspector from Region V ccaducted an

- announced inspection to review information concerning classification of

rocurements and verification.of vendor furnished Certificates of Compliance

-p(C of Cs). In addition, the licensee's response to the-four Unresolved Items

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'(URIs) identified in Report No. 50-344/85-025 were reviewed.

The inspection involved 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> by two (2) NRC inspectors.

Results: The inspection substantiated the Potential Enforcement Finding

previously identified in Report No. 50-344/85-025 in the area of safety-

related procurement. Of the four URIs identified in Report No. 50-344/85-025,-

URIs 344-85-025-05 ar.d 344-85-025-06 were closed and 344-85-025-03 and

344-85-025-04 remain open.

DETAILS

1. PERSONS CONTACTED

Portland General Electric Company (PGE)

J. Lentsch, Manager, Nuclear Safety and Regulation

• A. Olmstead, Manager, Quality Assurance

A. Ankrum,-Nuclear Engineer

M. Cooksey, Section Supervisor, Electrical Engineering

• Denotes those individuals who attended the exit meeting.

2.- -BACKGROUND INFORMATION

.The purpose of this followup inspection was to address concerns expressed

- in the licensee's response, dated October 14, 1985, to Report No. 50-344/85-025.-

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The concerns were that the inspection team performing the August 9 and

12-16, 1985 inspection had incorrectly interpreted the licensee's procurement

requirements and equipment classification system, and had overlooked some

information concerning the licensee's efforts to verify the validity of

vendor furnished C of Cs. In an effort to resolve these concerns, the l

inspectors discussed the concerns and the licensee's response with the

licensee, and reviewed the additional information provided by the

licensee in the aforementioned areas.

3. Potential Violation; 344-85-025-01 (Procurement)

a. Initial Inspection j

In order to select safety-related modifications to review for

procurement and post-installation testing, the inspectors requested a

listing of safety-related " requests for design change" (RDCs). A

computerized printout of RDCs titled "RDC Log (Q-List Sort)" was

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provided. The definition of "0-Listed" appearing on page G-8 of

Revision 10 of PGE's Nuclear Quality Assurance Program is stated

as: " ...The Q-List identifies a systems, structures, and

components which...have been detennined to be safety-related. The

Q-List enumerates safety-related systems, structures, and components

to which the QA program applies." Attachment E, " Guidelines For

Determination of Safety-Related Purchase Requisitions", to NPEP

300-1, " Procurement Procedures for Nuclear Power Plant Modifications

and Additions," states that if the purchase requisition is the

result of a safety-related RDC, the purchase requisition i; to be

considered safety-related. Based on this information, the

inspectors concluded that equipment being procured for the

safety-related RDCs reviewed was to be considered safety-related.

From the "Q-List" RDC Log provided, the inspectors selected ten ROCS

to review in depth, from procurement through post-installation

testing. From the ten RDCs, the inspectors selected ten components

and reviewed the procurement packages for these ten components (see

Table 1, pg 4 of Report 85-025). PGE had classified the components

as QA Code 0 which, under PGE's procedure NQAP-105, meant that PGE

could and did purchase the components without imposing any quality

program requirements on the manufacturer or evaluating the manufacturer's

quality assurance program. The components were accepted based on a

C of C from the manufacturer.

Regulatory Guide 1.123 (Rev. 1) " Qual'ity Assurance Requirements for

Control of Procurement of Items and Services for Nuclear Power

Plants," which endorses ANSI N45.2.13-1976, which PGE committed to

in their FSAR, allows purchases based on C of Cs provided that the

purchaser verifies the validity of the C of C.

Paragraph 10.2.f of ANSI N45.2.13 states: "Means should be provided

to verify the validity of supplier certificates and the effectiveness

of the certification system, such as during the performance of

audits of the supplier or independent inspection or test of the

items."

Curing the August,1985 inspection, PGE's position was that since

they were purchasing off-the-shelf catalog items, i.e., commercial

grade under 10 CFR 21, the quality requirements of Appendix B to 10

CFR 50 were not applicable. They stated that the detailed review of

the original environmental qualification test report for the component,

and the receipt and post installation testing performed on the components

by PGE verified the validity of the C of C.

The inspectors' position was that since PGE had specified the

requirements of IEEE-323 and/or IEEE 344 (specifications unique

to the nuclear industry) in the purchase orders for the ten

components, the components did not meet all the tests for commercial

grade under 10 CFR 21. The quality requirements of 10 CFR 50,

Appendix B, therefore, are applicable, and the applicable requirements

should have been imposed. In reviewing PGE's receipt and post

installation test requirements, the inspectors determined that the

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testing would not verify that the components would meet the

requirements of IEEE-323 or 344, since the tests were conducted in

a normal environment, (i.e., ambient temperature, humidity and seismic

conditions) rather than under the conditions required to satisfy

Trojan's seismic response spectra or environmental qualification

requirements.

Therefore, with no evidence to show that the manufacturer had

maintained the qualified configuration for the component or that PGE

had verified the validity of the C of C, PGE was found to be in

noncompliance with Appendix B, and their FSAR commitments.

b. Followup Inspection

Based on PGE's response to Inspection Report 85-025, a followup

inspection at PGE was conducted on October 30-31, 1985. PGE's

response, dated October 14, 1985, stated that a number of the

components listed as safety-related in Table 1 of Inspection Report

85-025, were, in fact, not safety-related. In addition, PGE modified

their position that no quality requirements were necessary for 0A

Code D items on which the additional requirements of IEEE-323 and

344 had been imposed. Their response stated that IEEE-323 and 344,

themselves, imposed the applicable QA requirements and therefore,

imposition of Appendix B was not necessary.

To substantiate their position, PGE showed the inspectors their

equipment "Q-List", i.e., those pieces of equipment considered

safety-related. PGE noted that the two pieces of equipment

highlighted in Paragraph 3.c of inspection report 85-025 (an RCS

pressure recorder and a square root extractor for the AFW system)

were not listed in the equipment "Q-List" and were therefore not

safety-related. In later discussions between the inspectors and

personnel in the Instrumentation and Control Systems Branch of the

Office of Nuclear Reactor Regulation, it was determined that the RCS

pressure recorder is safety-related and should have been listed in

the' equipment "Q-List".

The purchase order for the RCS pressure recorder was issued to

Branom Instruments and specified a pressure recorder manufactured by

Texas Instruments (TI). Neither company had been audited or appeared

on PGE's Evaluated Contractor and Supplier List (ECSL). The purchase ,

orders from PGE to Branom and from Branom to TI imposed IEEE-344-1975  ;

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and required a Certificate of Conformance attesting to the fact that

the specification had been met, but no additional quality requirements

were imposed. As previously stated in paragraph 3.a, PGE's QA

program and FSAR commitments required them to verify the validity of l

the C of C through audits of the supplier or independent inspection

or test of the items. PGE had not performed an audit at Texas

Instruments and Mark Cooksey, the Electrical Engineering Section

Supervisor, stated that the testing performed by PGE did not, nor was

it intended to, verify the ability of the equipment to function

during or after a seismic event. Since PGE did not adequately

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.- verify the validity of the RCS pressure recorder through testing or

inspection,-and the manufr.cturer did not have a quality program

' meeting the applicable portions of Appendix B (see Inspection Report

99901028/85-01), the potential violation of the requirements of 10

CFR 50 Appendix B identified in Inspection Report 85-025 is

considered valid.

.In preparing this report, the inspectors again reviewed PGE's

position on imposing Appendix B requirements to supplement those

contained in IEEE-323 and IEEE-344. A thorough review of IEEE-344

was performed and it was concluded that IEEE-344 contained no

-quality assurance requirements. A thorough review of IEEE-323 was

also performed, particularly the first paragraph of Section 4,

" Introduction", which is the reference PGE based their position on.

The first paragraph states

"The manufacturers and users of Class 1E equipment are required to

provide assurance that such equipment will meet or exceed its

t performance requirements throughout its installed life. This is

, , accompl_ished through a disciplined program of quality assurance that

includes but is not limited to design, qualification, production,

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quality control, installation, maintenance, and periodic testing.

This document will treat only the qualification portion of the program."

The last sentence of the paragraph quoted above clearly states that

IEEE-323 does not impose any of the other elements listed. The other

elements listed are only intended to provide guidance to the purchaser

as to what is necessary in the way of controls. Therefore, PGE's

procurement procedures were inadequate in that they failed to impose

the applicable portions of Appendix B when IEEE-323 and IEEE-344 had

been imposed or to separately qualify each item purchased.

Drafts of five new Nuclear Division Procedures designed to strengthen

PGE's procurement program were reviewed and appeared adequate. The

inspectors also reviewed the list of vendors which PGE had used recently

but was not able to place on their ECSL by means allowed under their

QA program. It was determined that four of the vendors provided

safety-related services (three calibration services vendors and one

nondestructive examination service vendor). PGE was in the process of

scheduling audits at these vendors at the time of the inspection.

4. - Potential Violation 344-85-025-02 (Part 21)

The inspe'ctors reviewed PGE's revised Part 21 procedure and determined that

it was adequate. However, the position on the appl.icability of 10 CFR 21

as stated in the PGE response to Inspection Report-50-344/85-025 is

incorrect. Because PGE imposed IEEE-344 and IEEE-323 in 'the purchase order

for the circuit breakers, all three conditions stated in paragraph 21.3(a)

(4)(a-1) for determiling commercial grade have not been met. According

to paragraph (a-1)(1), if an item is subject to design or specification

requirements unique to facilities licensed pursuant Part 50, the item is

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not commercial grade. IEEE-323 and IEEE-344 are specifications unique to

facilities licensed under Part 50. They are titled " Qualifying Class IE

Equipment for Nuclear Power Generating Stations" and "IEEE Recommended

Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power

Generating Stations." As such, PGE's procurement procedures fail to assure

that Part 21 is imposed when specifications unique to facilities licensed

under Part 50 are imposed.

5. Unresolved Item 344-85-025-03 (Nonconforming Material)

PGE's response appears adequate, however, the revised procedures had

not been completed at the time of the inspection. This item remains

unresolved.

6. Unresolved Item 344-85-025-04 (Terry Turbine)

PGE's response indicated that the proper fasteners and alignment pins

have been installed. However, the response does not address the issue of

whether the turbine configuration as found met the seismic qualification

requirements for Trojan. This item remains unresolved.

7. Unresolved Items 344-85-025-05 and 06 (Incomplete Test Data) *

The inspectors reviewed a report of an audit performed by PGE of the

adequacy of testing and test documentation. The audit covered the-areas

noted in Inspection Report 85-025 as having incomplete documentation of

test results. The audit team was able to locate all the test documentation,

with some difficulty, and ascertain that all necessary testing was performed.

However, the QA Manager informed the inspectors that changes were being

made to procedures to assure that this type of documentation will be more

easily retrievable in the future.

These items are considered closed.

8. EXIT MEETING

The insp'ectors met with Mr. A. Olmstead on October 30 and 31, 1985, to

summarize the scope and findings of the inspection.

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