ML20147C375
| ML20147C375 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/01/1988 |
| From: | SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20147C352 | List: |
| References | |
| NUDOCS 8803030062 | |
| Download: ML20147C375 (71) | |
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PI?OCUREMENT - ENGINEERING fASSESSMENT: PLAN I N T E R I M'.. R E P O R T s
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RANCHO SECO-NUCLEAR: GENERATING STATION SACRAMENTO MUNICIPAL UTILITY. DISTRICT r.
4 March 1, 1988
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a PROCUREMENT ENGINEERING ASSESSMENT IN'"ERIM REPORT TABLE OF CONTENTS Page No.
I.
Executive Summary 1
II.
Introduction 3
III.
Background
4 IV.
Procurement Engineering Assessment Plan 6
V.
Commercial Grade Item Evaluation (57 Packages) 8 VI.
SEQ of RPS and SFAS Relays 11 VII.
Piece-Part Environmental Qualification 13 VIII.
Enhancement of Existing Procedures / Training 17 IX.
Green Tag Program 19 X.
Resolution of NRC-Identified Discrepancien 21 XI.
QA/QC Surveillance of Selected Actions 23 XII.
Overall Results 24 XIII.
Conclusions 29 XIV.
Attachments A1 - A7
I.
EXECUTIVE
SUMMARY
This report provides the interim (pre-restart) results of the Procurement Engineering Assessment Plan (PEAP).
During December, 1987, the CEO, Nuclear of Sacramento Municipal Utility District (SMUD) directed the establishment of a Procurement Engineering Assessment Team wit h the mission to evaluate past and current material control practices and to recommend actions
.iecessary for improvement.
The team was provided with manpower and access to r.ecessary site resources to sucessfully accomplish-its mission.
The Procurement Engineering Assessment Plan (PEAP) describes the methodology and specific objectives related to this effort.
One of the primary objectives of the PEAP was to provide Rancho Seco management with enhanced confidence that installed equipment meets design requirements.
The PEAP was subsequently revised to address additional concerns identified by the NRC procurement team during their January 1988 inspection.
Additional concerns centered on recognized weak practices involving commercial grade item procurement.
The PEAP restart issues were:
A.
Commercial Grade Item Dedication B.
Seismic Qualification of Reactor Protection System (RPS) and Safety Features Actuation System (SFAS) Relays C.
Piece-Parts Environmental Qualification D.
Enhancement of Existing Procedures / Training of Personnel E.
Acceptability of Class I warehouse stock (Green Tag Program)
With the exception of Item D above, each issue was addressed by performing technical evaluations on a sample of selected components / parts installed or available for installation in Class I systems.
These technical evaluations were conducted in eccordance with detailed instructions.
For issues A, B,
and C, the evaluations consisted of ensuring that parts procured as commercial grade items did not adversely impact the safety function of systems / components.
Issue E was addressed by evaluating the adequacy of Class I warehouse items available for installation.
Issue D involved a comprehensive review and rewrite effort to enhance procurement-related procedures and to develop an associated training program.
The interim results of the PEAP demonstrate that the safety function of installed equipment has not been adversely impacted by past procurement practices.
Out of approximately 1,300 items representing a broad spectrum of equipment and replacement parts, j
only two EQ parts require removal and replacement.
These are comprehensive evaluation of isolated cases.
In each case a l
problem cause and extent has led to a positive conclusion supporting plant restart.
1
e.
Based on our review, Rancho Seco Management believes that a reasonable level of. confidence has been demonstrated to support safe plant operation.
Additional long-term action to further this confidence 1 1s as follows:
A.
Complete Stock Material-Reverification (LER 85-14) to include results of this PEAP effort.
B.
Complete Technical Evaluations for remaining EQ components.
C.
Complete review of previously prepared Commercial Grade Dedication Evaluations to the newly revised program.
D.
Provide Personnel Training at appropriate levels.
E.
Continued evaluation of generic technical or programmatic issues that are identified during this review.
This report contains a summary discussion and conclusion ~on each pre-restart issue followed by complete details in separate attachments to this report.
Post restart evaluations are scheduled for completion by June 1988.
Progress reports on these efforts will be prepared periodically (approximately monthly) with a final report scheduled for June 30, 1988.
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II.
INTRODUCTION The Procurement Engineering Assessment Plan (PEAP) was developed to provide additional confidence to Sacramento Municipal Utility District (SMUD) management that the as-installed configuration of Rancho Seco is consistent with plant safety requirementr.
'in e PEAP also addresses specific concerns identified by SMUD and ihe NRC.
These concerns resulted from admittedly weak procurement and material control practices in the past that have recently been strengthened through the implementation of various improvement programs.
The PEAP consists of three phases.
Phase 1,
a review of plant problem reports, and Phase 2, a pre-restart evaluation of the use of commercial grade items in safety related systems, are to be completed prior to restart.
These efforts were undertaken to provide additional confidence that the safety function of Quality Class I systems and/or components has not been impacted by past material control practices.
The results of Phases 1 and 2 are provided in this interim report.
Phase 3 is an ongoing implementation of the PEAP and of corrective actions committed to in LER 85-14 as well as other actions designed to enhance the long-term performance of the material control process.
This third phase will continue past restart and is indicative of SMUD's commitment to excel beyond minimum requirements.
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7 III.
BACKGROUND During December 1987, SMUD's CEO, Nuclear directed the establishment of a Procurement Engineering Assessment Team with the mission to evaluate past and current material control practices and to recommend actions necessary for improvement.
The team was provided with manpower ar.d access to all site resources as needed to sucessfully accomplish its mission.
A Procurement Engineering Assessment Plan (PEAP) was formulated to describe the methodology and specific objectives related to this effort.
One of the primary objectives of the PEAP was to provide Rancho Seco management with enhanced confidence that installed equipment will meet design requirements.
The PEAP was subsequently revised to address additional concerns identified by the NRC procurement team during their January 1988 inspection.
This report provides the interim results of this plan.
Ti e programmatic weaknesses identified by SMUD and the NRC are categorized as follows:
o Inadequacies in the past practice of procuring commercial grade items based on the "Like-for-Like" acceptance method.
o Procedural discrepancies and lack of clarity.
o Approval of vendors based solely on desk audits.
o Other procurement-related concerns involving specific equipment and/or practices.
Positive aspects were also noted, mainly in the area of previously commissioned studies and programs which were related, either directly or indirectly, to materials management.
These programs identified some deficiencies and contributed to improved practices.
More significantly, these programs provided managemer t with a high level of confidence that materials and equipment installed in the Rancho Seco Nuclear Generating Station would perform their intended safety functions.
These programs included:
o Assessment of Materials Management Practices o
Expanded Augmented System Review and Test Program (EASRTP) o Engineering Evaluation of the Suitability of Installed Equipment o
Sjatom Review and Test Program (SRTP) 4
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~-However,L thefabove programs and studies as 'well :as, pastiaudits '
(both' internalandlexternal). did not focus specifically on
..Commercia1{ Grade--Item DedicationJ(CGID).
Duel to; weak: practices..
s
",. Tinithe~past'concerning this. process, SMUD. management decidedithat'
,X Ladditional' evaluations were desired tofassess/the impactiof-paste CGIDLpractices'.onaplantIsafety,and'to again.further,-enhance management's' confidence'in the: adequacy of-. installed' material ~and
- equi'pment.,1The ' PEAP was :therefore-developed to meet this objective,;to; address.the NRC, inspection concerns,'and toten'sure that SMUD-initiated'c'orrective.actionsLare being implemented.in_a 1timelygmanner.
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A IV.
PROCUREMENT ENGINEERING < ASSESSMENT PLAN A.
Objective The' Procurement Engineering Assessment Plan (PEAP) delineates a comprehensive effort.to address concerns and observations related to Procurement and Materials Control issues.
The primary' objectives of the assessment plan are:
o' Provide a higher degree of confidence that the as-installed configuration of Rancho Seco is consistent with plant. safety requirements, o
Address concerns identified by the NRC Procurement and Materials Control Inspection.
o.
Ensure that long-term corrective actions designed to enhance the Procurement and Materials Control processes are aggressively pursued.
B.
Scope The PEAP addresses both specific and generic actions on both a restart and long-range action basis.
The plan is' divided into three phases:
Phase 1 A review of plant problem reports to determine if Commercial Grade Item failures caused or contributed to past operational problems.
Phase 1 was completed on January 29, 1988.
Results showed there was no link between past operational problems (trips, transients, etc.) and commercial grade procurement practices.
Details on Phase 1 are provided in Section XII of this report.
Phase 2 A pre-restart technical review to enhance the confidence of SMUD management in the adequacy of as-installed equipment and address specific areas of concern.
Phase 2 commenced on January 14, 1988 and addresses the following issues:
1.
Commercial Grade. Item Dedication (CGID).
2.
Seismic equipment qualification (SEQ) of relays in the Reactor Protection System (RPS)and Safety Features Actuation System (SFAS).
3.
Piece-part environmental qualification (EQ).
4.
Enhancement of existing procedures / processes.
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.a 5.
Resolution'of NRC-identified concerns including the warehouse stock acceptance (Green Tag) Program.
Phase 3 An ongoing long-range effort to continue the technical evaluations, programmatic improvements, and verification efforts initiated in the second phase.
Phase 3 activities-are summarized into five primary areas, along with their scheduled completion dates:
1.
Stock material reverification (LER 85-14).
9-30-88 2.
Complete technical evaluations initiated 6-30-88 in Phase 2.
3.
Continue procurement training.
Ongoing 4.
Complete acceptance evaluation of 4-15-88 previously performed CGIDEs to the newly revised program.
5.
Conduct QA surveillances on specified 30 days completed actions.
after completion C.
Organization The functional organization utilized to support the PEAP is depicted on Attachment 1. The lead personnel supporting this effort were specifically selected for their background and expertise related to materials management and procurement issues.
This approach provided SMUD with a highly specialized team of professionals knowledgeable in all facets of these issues.
These lead personnel were supported by both SMUD and contractor personnel.
All technical team members were trained on procurement / materials control processes, terminology, and assessment methodologies.
D.
Procedures / Instructions i
In addition to procedures in place at Rancho Seco for procurement and materials control, specific instructions were generated to def.no the assessment plan implementation methodology.
These instructions were ERT-05 "Engineering Evaluation of Previously Installed Commercial Grade Items in l
Safety Related Systems" and ERT-06 "Sample Evaluation of I
Class I Warehouse Stock Currently Available for Issue".
All team members involved in each assessment activity were l
provided copies of these instructions and trained as j
appropriate.
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V.-
COMMERCIAL GRADE ITEM EVALUATION The1following summary provides a general assessment of the use of commercial grade items in safety related systems at Rancho Seco since the inception of the definition of "commercial grade item" and "dedication" in 10CFR21, "Reportinglof Defects and-Noncompliances".
Details of'the assessment can be found in to this report.
A.
Objective To assess the overall impact of past commercial grade item dedication (CGID) practices employed on commercial grade items used in safety related systems since the revision of 10CFR21 in 1978.
This assessment is designed to address various types of spare and replacement items procured as commercial grade and installed in Class I systems.
In addition to this are two specific assessments of the use of commercial grade items in safety related seismic and environmental equipment qualification applications.
These assessments are discussed in Sections VI and VII, respectively.
B.
Scope A group of work requests potentially involving installation of commercial grade items in Class I systems during the period 1978 through 1986 was surveyed.
From this
-"c; representative number of work requests were seler.ed involving the installation of commercial grado items.
The selection involved 136 work requests generated daring this time frame of which 57 were selectively chosen by the NRC for evaluation during their Procurement and Materials Control Inspection of January 4-14, 1988.
Rather than extend the evaluation to all 136 work requests, a decision was made during the NRC's January 1988 inspection to perform expanded evaluation of EQ piece parts and seismic relays.
C.
Methodology A document package was developed for each work request selected by the NRC for their evaluation.
The packages contain'ed information relating to equipment, plant system, item pu* chase v. Jar documentation, inspection records, etc.
These packages were then reviewed by the NRC for their evaluation of the adequacy of past commercial grade item dedication practices employed by Rancho Seco.
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D.
Resultn The work requests reviewed by the NRC involved over 230 commercial grade items.
These items were analyzed and found-to be representative of the broad spectrum of the typical commercial grade items installed in Class I systems during the specified time period.
The NRC evaluation of past practices employed by Rancho Seco in the use of commercial grade items were satisfactory with the exception of questions raised on seven specific work requests.
All questions have been subsequently resolved, however two were resolved through the generation and disposition of two Nonconformance Reports.
A description of these two items are as follows:
1.
WR 97391 - Ohmite Relay in the DCS Battery Charger This work request involved the replacement of a relay in the battery charger.
The vendor's bill of materials and recommended spare parts list specified an Ohmite Model No. DOX-46T, 3 pole / double throw relay for this application.
The current installed relay is an Ohmite Model No. DOX-480, 4 pole / double throw.
The dedication for this relay was based on a "like-for-like" determination.
No existing documentation which authorized the change in plant configuration from the originally supplied and qualified DOX-46T to the currently installed DOX-480 was found; thus, an NCR was written against this relay.
This resulted in a new commercial grade item dedication evaluation being performed.
Based on an analytical systems evaluation, chatter evaluation, and a similarity analysis between the two relays, it was determined that the DOX-480 was acceptable for this application.
The formal commercial grade item dedication has been completed which documents the adequacy of the DOX-480 relay and also forms the basis for NCR closure.
2.
WR 68932 - GE Relay in the Reactor Sampling System The replacement relay was a commercially procured GE relay FGEF-4210 (CR2820A14AT-22).
The relay is currently being dedicated by General Electric via performing a similarity analysis between the relay currently installed and a similar relay installed in a motor control center that has undergone a qualification test.
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9' E.
Conclusions The evaluation of commercial grade item applications since
-1978 concluded that of.over 230 items, questions were identified on 7 specific items. -In each case, these 3'
questions were either rese1ved o, in the case of the GE relay,_are in the process ot-being resolved with a conclusion that plant safety h.,d not been impacted.
In the two cases cited above, additiont i. engineering analysis was required to substantiate the the' installed equipment and to properly document the conclusions reached.
We believe that the range of items by type, years of installation (1978-1986) and types of issues identified supports our conclusion that our plan (PEAP) phase II survey is representative.
The results of CGID evaluations from this group will be coupled with ths EQ and SEQ analysis (Sections VI and VII) to support any overu31 conclusions reached.
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- VI.
SEISMIC EQUIPMENT QUALIFICATION (SEQ) OF REACTOR PROTECTION SYSTEM (RPS) AND SAFETY FEATURES ACTUATION SYSTEM (SFAS) RELAYS
/A summary of the assessment of the use of commercial grade replacement relays in the RPS and SFAS is provided below.
Complete details of the assessment can be found in Attachment 3 to this report.
A.
Objective To assess the acceptability of commercial grade replacement relays used in the RPS and SFAS.
B.
Scope All relays in the RPS and SFAS were researched to identify those that were modified or replaced with commercial grade relays since system installation. Nuclear Engineering Department Report (ERPT E-0316) defines the methodology used to identify the total number of relays in the RPS and SFAS.
The number of relays in these systems totaled 1,114.
C.
Methodology A complete work history review was performed to identify those relays that had been replaced or modified since installation of the systems.
Of the 1,114 relays in the two systems, the work-history review disclosed that no relays had been modified or replaced in the RPS and 21 relays had been installed as either new additions or replacements in the SFAS since installation of the systems.
These relays were then evaluated to determine whether they were procured as commercial grade and to assess the impact of any commercial grade replacements on seismic qualifications in accordance with procedure ERT-05, "Engineering Evaluation of Previously Installed Commercial Grade Items in Safety-Related Systems".
D.
Results The evaluation of the relaya disclosed that of the 21 relays modified, added or replaced in the SFAS, 3 had been procured as QA Class I, one was found to have no impact on system safety function and the remaining 17 were commercially procured.
Those that were commercially procured were satisfactorily dedicated for their specific applications.
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E.
Conclusions
^
Based on the review of'the.1,114 relays'in.the RPS and SFAS and.an assessment of the replacement relays, it was
~ concluded that the use of. commercial grade replacement relays was acceptable.and did not affect system safety or functionality.
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.g' VII.
PIBCE-PART ENVIRONMENTAL QUALIFICATIONi(EQ).
The-following summarizes the assessment of the use of commercial gradegreplacement parts in environmentally-qualified equipment.
- Complete details of the assessment.can be found in Attachment'4 to-this report.
A.
Ob.lective To. verify acceptability for various EQ applications cf replacement parts procured as commercial grade ana accepted based on a like-for-like evaluation.
B.
Scope The piece part evaluation applies to all F.4 replacement parts procured as commercial grade and installed r'nce Nuvember 1985..A work history review was perforn3d on all EQ equipment since November 1985.
The review indicated that for the 484 EQ equipment tag numbers, 1085 work requests were issued for which field work is essentially complete.
An engineering review of these work requests identified 739 work requests involving parts replacement or modificatians.
This population represents the group of work requests on which an evaluation of the adequacy of Commercial Grado
' Items in EQ applications is being performed, C.
Methodology The EQ Master List, as defined by Engineering Report ERpT-E0177, was utilized to define the equipment tag nurabers whose work history would be reviewed.
This list of tag numbers was subdivided into eleven categories.
For each category, a work request history review was performed to identify any modification or maintenance work that had been performed since November 30, 1985.
The purpose of this was to identify the use of commercial grade items in EQ applications and evaluate the impact on the qualified status of the eqaipment.
Those work requests that involved replacement of itecs were then subjected to an evaluation per the requiremer.ts of ERT-05.
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- c D.
Results To date, 186 work requests have beeti reviewed with'_155 currently summarized ai.d in the approval-process.
Of the-155.-20 commcreial grade item dedication evaluations have been or are i s, the process of'being generated.
A sunimary of the parts ass:. lated with the 155 work requests'in the approval cycle.'iw as follows:
Work Parts-Parts Required
- Categotr Requests Parts Q1
-C G -
Replacement MOVs 33 21 10 11 0
Solenoids 23 40 36 4
0 Transmitters 25 44 21 23 0
Limit Switches 4
0 0
0 0
Miscellaneous 30 29' 28 1
0 Ilydrogen Analyzers 15 21 2
19 2 (Asco kil, Vin)
Cable, Splices, 0-0 0
0-0 Terminal Blocks Feedthrough'
'3 73 0
73 0
Penetrations Motors 7
3 2
1 0
H Recombiners 7
8 0
8 0
2
-Acoustic Monitors 8
14 0
14-0 Totals 155 253 99 154 2
The review-thus far has-resulted in three Nonconformance Reports (NCRs) as follows:
NCR 7772 - ASCO Coil in the Hydrogen Monitor Solenoid The hydrogen monitor panel H-4HMB currently contains a solenoid valve with an incorrect coil.
The coil is not the high temperature Class H coil which has been qualified by the vendor in EA&T Test Peport 1035-1.
As a result, the coil in question is being replaced.
Investigation of this condition and its associated root cause determined this to be an isolated occurrence in that the stock identification number for the coil applies to coils used in the hydrogen monitors only and the stock code inadvertently omitted the designation "THT" as a prefix to the manufacturer's coil number.
Further review of all solenoid valves in EQ applications indicates no other occurrence of this condition, nor has there been any evidence of incorrect stuck card designations in any of the other 154 work requests in the approval process, i
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NCR 7775 --Accelerometers and Cables in the MSS' Acoustic Monitors The acoustic monitors associated with the atmospheric dump valves for position indication in the Main Steam Syntem were r
repaired by replacing.the' accelerometers and associated' cabling-with Class II items.
Class II items were used because.the equipment Is in fact on a' Class II system; however, the equipment was placed on the 10CFR50.49. master list based on Reg Guide 1.97 Category 2 qualification requirements.
The replacement of these items with
-unqualified Class II items caused the qualified status of the equipment to be-indeterminate.
An assessment of the need to include these accelerometers in the 50.49 list has determined that they can be removed from the list because they were installed in response to NUREG 0737 and SMUD does not consider them to be a Reg Guide 1.97 Category 2 variable.
An assessment of the root cause for this condition' indicates that the condition occurred as a result of the purchase, receipt and. installation of the items as Class II,.which was consistent with the QA classification of the equipment.
A review of all Class II EQ identified items on the Master List and their associated work histories has been accomplished and no other instances of using commercial grade parts have been identified.
Further, an investigation of all-accelerometers and cabling associated with the Master Equipment List and the corresponding stock issue has been performed to assure that installation in Class I applications has not occurred.
This investigation has determined that no installations of non-Class I accelerometers and associated cabling in Class I applications have been performed.
NCR S-7788 - Wiring in the Hydrogen Monitor Cabinet Heater The containment hydrogen monitor local panel (H-4HMA) contains power wiring to the heater elements that is not in conformance with the vendor drawings.
The associated work request replaced the heater wires with #14 SIS nuclear grade wiring.
The inspection of the work performed on the work request was conducted using a vendor drawing which did not specify that #16 AWG silicone insulated wiring be used for the heater circuits inside the hot box assembly.
Based on a walkdown of hydrogen monitor H-4HMA, the power wiring to the heaters has been replaced with #14 AWG Rockbestos Firewall SIS 600V wiring which is rated at 90 C and is qualified to the requirements of IEEE-383.
The manufacturer of the hydrogen analyzer (COMSIP, Inc.) has informed SMUD that all wiring located in the heated sample compartment (hot box) of the containment moritoring system installed in Rancho Seco must be 16 gauge BIW silicone wire (the originally qualified wiring).
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.During the walkdown it'was further observed that the
' insulation on'the Rockbestos Firewall SIS and' AMP lugs inside-the hot. box assembly had deteriorated due to over heating.
This wiring is not designed to withstand
' continuous exposure to the temperature environment-in the hot tox assembly (285 F).
As a result of this' condition, an NCR was' generated and-dispositioned to replace the wire.
_Our-root-cause analysis concludes that this condition is isolated to the specific vendor drawing-being ambiguous regarding the lack of design information for the wiring routed inside the hot box assembly.
Improper wiring was utilized because the information was not available tu aid in the selection and inspection of the wiring replaced under Work Request No.
117355.
This occurrence is considered to be limited to the
.COMSIP hydrogen analyzers.
To assure that this condition did not exist in.the other analyzer (H-4HMB), a review of work-history and a walkdown was performed.
These reviews concluded that no wiring changes have been performed and the proper wire,is installed.
E.
Conclusions Based on the results of the 186 work requests reviewed to date and the disposition of the three associated NCRs, it has been-concluded that the use of commercial grade items has not degraded plant safety and that the environmental qualification of equipment subject to 10CFR50.49 has been raain tained.
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VIII.
ENilANCEMENT:OF EXISTING PROCEDURES / TRAINING 7
A summary of the efforts associated with the enhancement of existing procedures / training is provided below.
Complete details can be found in Attachment 5 to this report.
A.
Objective To clarify and strengthen the controls for procurement-related procedures.
B.-
Scope Enhancements were made to clarify and strengthen the controls for Class I, Procurement Level 3 activities.
This effort involved the reissue of the procurement level control procedure as a plant level procedure and the addition of supplemental guidance for engineering evaluation of Procurement Level 3 items.
In addition, other procurement-related procedurcs were reviewed to resolve noted discrepancies such as incorrect references.
C.
Summarv of Revisions The following is a brief synopsis of revisions made to the Material / Procurement Control procedures.
1.
Added definition for a "Generic Dedication".
Deleted separate reference to EQ/ SEQ items - these items have the same requirements as QA Class I items.
Deleted all Generic Items which were listed as not requiring dedication - these items will now be dedicated on a Commercial Material Evaluation (CME) as a "Generic Dedication".
2.
The Quality Related Item Evaluation review was added to address the definition of characteristics important to function for items being purchased through Procurement Level 4.
This strengthens the method by which the critical characteristics are defined / verified prior to procurement.
3.
Eliminated like-for-like verification as a means to accept a commercial grade item.
Critical characteristics for identical replacements are verified.
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i, D..
Training of Personnel A. comprehensive training program'is under deve'lopment for Engineering and Material Control / Procurement personnel.
The program covers Procurement and Engineering evaluations, particularly Commercial Grade Item Dedication and the Class I, Level 3 purchase process.
This training program will be in place with-specific training to the new procedures initiated-prioP.to-plant restart.
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GREEN-TAG PROGRAM s
-A summary of the assessment of the Green Tag. Program is provided-
.be16w.
Complete-details.of this assessment effort can be found in
Attachment:
6 to. this report.
A.
Ob.iective To provide assurance that Class I items which are available for issue from the warehouse (s) for plant installation have the required procurement and inspection documentation.
r B.
Scope A survey of such items was initiated.
The population consists of approximately 100 items presently in the warehouse which were procured prior to implementation of the current procurement program (1987), tagged as Class I, and available for issue.
C.
Methodology a.
Walkdowns of the warehouse (s) were performed to physically locate and examine existing Class I, non-commercial grade stock items b.
Items were chosen from different vendors, various purchase years and plant systems.
c.
An effort was also made to provide a sample which consisted of approximately 70% electrical items and 30%
nechanical items.
Individual documentation packages were prepared for each of the items.
All packages were reviewed by Procurement Engineering, Quality Engineering, and Nuclear Engineering for appropriate EQ/ SEQ documentation when necessary.
D.
Results l
As a result of the warehouse walkdowns which were conducted.
74 items have been identified that satisfy the selection criteria.
It is estimated that this group represents over 50 percent of the total items in the warehouse (s) which satisfy the selection criteria and are available for issue.
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Documentation packages.fMr 50 of'these items have been completely reviewed and were found satisfactory.
The remaining are still in'the. review process.
Two NCRs have-been. issued.f7riitems with inadequate documentation.
These items.have been evaluated..by Nuclear Engineering and subsequently dispositioned as acceptable.
This~ effort also' identified a program implementation deficiency in.that 10CFR21 requirements were not stated on a number'of-Class I purchase' orders.
This deficiency: is being.
addressed-by contacting all ClassDI suppliers since 1978 and requesting the vendors to verify thstLeven though Part 21 was not specifically imposed on them by~the purchase. order they were aware of the requirement and have either self--
imposed this requirement or have had it imposed by other customers.
This effort will substantiate that the intent of 10CFR21~has been met.
E.
Conclusions With the exception of the issue relating to implementation of 10CFR21, no sifnificant items have been noted during these reviews.
We believe that more than adequate assurance that Class I warehouse items available for issue have the required procurement and inspection documentation.
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r X.
RESOLUTION OF NRC-IDENTIFIED DISCREPANCIES The following provides a summary of the efforts associated with the. resolution of specific NRC identified discrepancies.
Complete details of these efforts can be found in Attachment 7 to this. report.
A.
Bergen-Patterson Snubbers - Vendor recognized the applicability of 10CFR21 and has provided SMUD-with documentation to that effect.
B.
NRW Pump Cable Qualification - NCR S-7631 and-ODR 88-0032 were generated to resolve this issue.
Test samples of the NRW cables supplied by NSSS/DIVESCO were satisfactorily tested to the requirements of Section 2.5 of IEEE-383 (1974).
C.
No Procedures for Disposition of Damaged or Dropped Materials - Materials Management Desk Instruction, MMDI-0043 "Handling Damaged Material" has been issued.
D.
Class I Bolts Located in Class II Bin. Potential Co-mingling of Class I/ Level IV Can Screws, and Class II Bolts Referenced to Class I Work Request - These discrepancies have been satisfactorily resolved.
See for details.
E.
Generic CGIDs (used for items such as grout, Unistrut product, valve packing, etc.) - SMUD is developing a retrofit action plan to upgrade materials in warehouse stock to the requirements of the newly approved generic CGIDs.
F.
CGID Evaluations Since 9/87 Program
- 1) CGID 04297 (Agastat Relay) - The relay could not be initially dedicated because documentation demonstrating seismic acceptability could not be located.
The relay will therefore be removed and seismically tested.
In its place, nuclear grade relays will be installed.
If the removed relay fails the test, addltional actions associated with generic implications will be taken.
- 2) CGID evaluations made in accordance with the old process shall be reevaluated in accordance with ERT-05 and NEAP-4205.
This process is currently under way and is scheduled for completion by April 15, 1988.
21
e i ?!
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. G._ ' Vendor-Audit Program
.The supplier approval process has been revised to ensure that a program implementation evaluation (audit or survey) will occur prior to or dur.ing the "first significant" procurement activity.
22
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XI.
QA/QC SURVEILLANCE OF SELECTED ACTIONS The Quality Department was charged with conducting an audit of the Procurement Program.
The scope of this routine audit was modified to include an evaluation of selected elements of the
'PEAP.
-Specific elements included in the audit were:
l '.
' Assessment Plan Phase 1 Report on Findings which reviews possible procurement impact on SMUD trips or transients.
2.
The "Green Tag Validity Check" verification program.
3.
.The District Commitment Item I.A Phase 2 which includes a review of CGI replacement parts installed prior to the institution of the current "Dedication" program.
4.
The District Commitment Item TII Phase 2 which includes a review of CGID Evaluations from September 1987 to present.
The results of this audit will be documented in Audit Report 88-A-010.
Preliminary indications are that no significant findings or observations have been identified.
Additionally, the Quality Department performed a surveillance on the Green Tag Validity Check program.
They identified several concerns with the program including the adequacy of the population selected, the lack of procedures or instructions, and a failure of internal organizational interfaces.
The results are documented in Surveillance Report 88-S-114.
Each concern has been corrected with the solution incorporated into the current program.
23 m.
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s
-XII.
OVERALL'RESULTS A.
Results of Related Programs 1.
Expended Augmented System Review and Test Program The District's Expanded Augmented System Review and Test Program (EASRTP) was instituted as a commitment to the NRC to perform a comprehensive operabi'11ty assessment of 33 select systems.
The major objectives of this program are to assess the adequacy of activities and systems and evaluate the effectiveness of programs established to ensure safety during plant operations.
The program also assesses the adequacy of activities proposed to resolve identified problems with respect to restart, and the thoroughness of system testing recommendations.
To-date, all plant systems considered critical to plant safety (33 systems) have been reviewed and over 330 Requests for Information (RIs) have been generated to document questior.s or concerns.
The RIs cover a spectrum of' issues relating to system operation, engineering, maintenance, modifications, quality assurance, training, materials and warehousing, etc.,
as well as generic issues.
Numerous programs, procedures, and documents were reviewed, visual inspections of plant components made, and persons interviewed.
For example, over 800 procedures, 390 Engineering Change Notices, 1150 Work Requests, 300 calculations, 976 System Status Report (SSR) problems, and 260 Nonconforming Reports were reviewed.
Over 250 people were interviewed.
As EASRTP developed, specific attention was directed to the area of materials management.
Of the RIs issued, nine related to materials management issues resulting in 37 specific actions by Rancho Seco organizations -
17 to be completed prior to restart and 20 identified as post restart actions.
All issues related to Materials Management with potential safety significance have been closed.
24
Many of the Materials' Management related issues raised by the EASRTP investigation were identified with cn?
.have been factored into broad generic programs.
These programs include Environmental _ Qualification, MOVATS, Master. Equipment List (MEL) Upgrade, etc.
The EASRTP investigation also identified _ specific concerns including:
the. lack of an Engineering procedure for dedicat'ing commercial grade-items for use in. Class.1 applications and several instances where documentation appeared to be lacking-to support a commercial grade
-(or non-QI purchase) installed in a safety-related application.
All of the specific items have since been evaluated and found_to be acceptable.
In conclusion, the EASRTP investigation has focused management and technical attention on Materials Management issues.
Specific issues that may have impacted, system operability or safety have been resolved providing a hightened level of confidence in installed equipment.
Further, EASRTP has provided the genesis for further improvements in the area of Materials Management programs and processes.
2.
System Review and Test Program At the present time all safety related systems are undergoing an extensive functional and integrated test program to ensure both system and component operability prior to restart.
This System Review and Test Program (SRTP) has reviewed required safety functions and the capability of systems to accomplish these safety functions.
It has assured that Surveillance Procedures (SPs) properly tested all safety functions for operating equipment and has identified Special Test Procedures (STPs) for all functions not adequately covered by SPs.
This ensures the ability of the current safety systems configuration to meet all required normal and accident conditions.
In this manner, all past maintenance and modifications, including those related to Commercial Grade Items, will be functionally tested and their operability ensured.
Additionally, in accordance with procedures in effect at Rancho Seco, components in Class I systems which are removed from service for corrective maintenance are functionally tested prior to being placed back in service.
These tests are designed to ensure the component, including any associated parts, will satisfactorily perform its intended safety function.
This testing is in addition to and goes beyond routine maintenance testing.
Although these testing programs are not specifically applicable to commercial grade items, they do substantiate the as-designed and as-installed safety functions of Class I systems and components.
25
T
=
B.
Phase 1 Results The methodology utilized for.this phase involved the selection and assessment of individual recommendations contained in the "precursor review" data base associated with the Plant Performance and Management Improvement Program performed in 1986.
This data base includes extensive Rancho Seco and applicable industry history associated with transients, trips, and other events dating back to 1978.
By computer search of the original data base, a total of 388 individual recommendations arising from the precursor review group studies were identified which related to the 33 select systems.
Review of these recommendations identified a total of 47 Class I component failures which initiated or contributed to the severity of trips, transients and/or reportable events.
With the exception of items purchased for the inverters S-1A through E, and J, which were prestously identified prior to this review, there were no instances where a failure to perform to design or purchase specification requirements by a part purchased commercial grade contributed to past trips, transients, or other undesirable operating events.
The inverter problem has been resolved by removing the old inverters from service and replacing them with new, more reliable inverters equipped with static switching devices which prevent bus voltage interruptions when automatically transferring from a failed inverter to its on line backup.
Due to the unusual circumstances surrounding the inverters, including their inherently poor reliability in this application, the demise of the only qualified vendor of spare parts for the inverters, and the complexity of reconfiguring vital buss power supplies to alleviate the identified weaknesses, they are considered an isolated case.
Inverter failures are not indicative of a broader generic concern.
On this basis, SMUD management has additional confidence that the integrity of structures, systems and components currently installed at Rancho Seco have not been degraded by past commercial grade procurement practices.
26
[
e C.
Phase 2 Results Phase 2 was undertaken to enhance the confidence of SMUD management in the adequacy of as-installed equipment and to address specific areas of concern relating to procurement and material control practices.
Phase 2 was a comprehensive effort to review all outstanding issues related to commercial grade item installation which might adversely impact the adequacy of installed Class I equipment.
The reviews involved approximately 1,300 components representing a broad spectrum of equipment and replacement parts.
The following is a summary of the results categorized by the five major issues identified at the outset of Phase 2:
1.
Commercial Grade Item Evaluation o
57 Work Request Packages reviewed o
7 Issues raised - 5 considered acceptable o
2 Engineering Evaluations - 1 acceptable, 1 resulting in an NCR o
NCR dispositioned to dedicate item o
No parts replaced 2.
Seismic Qualification of RPS and SFAS Relays o
1,114 Relays identified o
21 Replacement Relays reviewed o
17 Dedications performed o
1 NCR, dispositioned as acceptable o
No parts replaced 3.
Piece-Part Environmental Qualification o
484 EQ components identified o
11 Equipment type categories o
186 Work Requests reviewed o
99 QA Class 1 & 154 Commercial Grade Parts reviewed o
20 Commercial Grade Item Dedicaticn Evaluations o
3 NCRs initiated; I acceptable o
2 parts replaced, determined to be isolated cases 4
Green Tag Survey o
71 Stock Items identi fi ed for review o
50 acceptable, 4 problems evaluated, remaining items under review o
2 NCRs initiated o
NCRs dispositioned as acceptable o
No parts replaced 27
yyw w-t.
15.
Procedures / Training o -18 procedures ~ revised'to update' references and.
-format o
4 procedures revised :to establish improved CGID controls.
e 1 new procedure to enhance the four level procurement system.
o 7 long-term enhancements identified o.. Training Program'under-way;? lesson. plans! completed
-for firstLphase o
Extensive training planned to assure all affected:
personnel receive indoctrination / training F
h l
28
XII.
CONCLUSIONS For the last year, SMUD has been engaged in a' comprehensive effort to upgrade current procurement and material control practices.
An integrated material control organization has'been i
.cstablished under the leadership of an individual experienced in implementing and operating effective material' control programs.
As noted in Section VIII of this report, extensive efforts have been made to institute new and revised procedures.
The result is an improved procedural program which provides effective controls and clear direction to personnel involved in the procurement-and material control processes.
A high level of-management attention has been directed at this program, not Just to meet minimum requirements but to excel in every-facet.
Program l implementation has further been enhanced through the establishment and use of the Materials Control Action Plan to ensure that all actions are effectively tracked and implemented.
Based on the results of our Phase 1 program and other related programs such as EASRTP and SRTP, SMUD considers that a high level of confidence in the suitability of installed equipment has been satisfactorily demonstrated.
The comprehensive and in-depth evaluation of the issues involved in Phase 2 has shown that the
-safety function of Class I systems and components has not been degraded.
SMUD is therefore reasonably assured that the goals
~
for plant' safety and operability have been achieved.
The results of Phtse 2 of the PEAP indicate that past procurement practices at Rancho Seco were weak especially in the area of commercial grade items.
These practices allowed the use of some items in Class I safety systems without thorough verification documentation to support such use.
The thorough evaluations conducted in Phase 2 dealt to a large extent with reconstituting or obtaining the necessary documentation.
However, out of the more than 1,300 components and parts identified / reviewed only two items were demonstrated to be unsatisfactory and are being replaced with qualified parts:
1)
A high temperature ASCO Coil in the hydrogen monitor solenoid was previously replaced with a coil not meeting the l
temperature requirement.
This case was determined, after review of all solenoid valves in EQ applications, to be isolated.
2)
A power wire in the Hydrogen Monitor Cabinet Heater was determined to have unacceptable insulation for its application.
This case has been isolated to this specific cabinet / vendor.
t With regard to our evaluations of previously purchased Quality
(
Class I material now in stock, results to date provide Management with confidence that current controls are effective in assuring that warehouse stock avullable for issue is adequately qualified.
b 29
Even with the high level of' confidence we have established in the acceptability of plant equipment, we believe that additional l
action is prudent to address other issues and to prevent
-recurrencefor discrept.ncies in the future.
Phase 3 is an
. extensive ongoing'prodram which has been established to accomplish such action.-. The primary tasks comprising Phase 3' along with their scheduled completion dates are provided below:
' 1.
Complete stock material reverification' 9-30-88 2.-
Complete piece-parts evaluation for all 6-30-88 EQ components 3.
Re-review all commercial grade-4-15-88 dedications to. current program 4.
Provide comprehensive training to-all ongoing personnel involved in procurement 5.
ContinuelQA surveillance on each major 30 days project task after Completion Phase.3 activities are being aggressively pursued and are indicative of SMUD's commitment to a sound procurement and Materials Control program.
In the implementation of the PEAP (Phases 1, 2,'and 3), SMUD has and will continue to focus i
management attention on roles, responsibilities, and resources to ensure effective and timely implementation.
The completion.of
~
Phase 3 will result in a procurement program which greatly exceeds regulatory requirements and industry standards and to which SMUD is committed to maintaining and improving as future conditions dictate.
B r
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ATTACBIEh7il PROCURmMNT ENGINEERIW3 ASSWSSMkti Pf.Ap FUNCTIONAL ORGANIZATION STRUCTURS PROJECT MANAGER DEPUTY l
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TECilNICAL l
MATERIALS l
l
-SUPPORT l
l DOCUMENTATION
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l QA/QE/QC CONTROL o
NRC Open o
Pull all o
Reverification o
Support Items / Interface Documentation j Validation Sampling i
o ' Procedures / Programs o
Level III o
Surveillances Program e
Training Program j
Review o
Collective Sirnificance/
o Engineering Interim & Finn 1 Reports Support NUCLEAR ENGINEERING i
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SYSTEMS l
EQ l
l SEQ i
EVALUATION I
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Relay Sample o
Item EQ Sample RPS/SFAS Validation o
CGID Sample Page A,1.I
[1 ATTACllMBNT 2
. COMMERCIAL GRADR ITEM RVALUATION L-b E
COMMERCIAL GRADE ITEM EVALUATION A.
Objective The Commercial Grade Item (CGI) Evaluation was initiated to assess the overall impact of past commercial procurement practices for items used in safety related systems since the issuance of 10CFR21.
This assessment is designed to address various types of spares and replacements procured over time as commercial grade Class I items.
Separate from this are two specific assessments of the use of commercial grade items in safecy related seismic and environmental equipment qualification applications.
These assessments are discussed in detail in Attachments 3 and 4 respectively.
B.
Scope A survey of work requests involving potential installation of commercial grade items in Class I systems during the period 1978 through 1986 was performed.
From this survey, a representative number of work requests was selected involving the installation of commercial grade items.
From a listing of these work requests, 57 were selectively chosen by the NRC for evaluation during their Procurement and Materials Control Inspection of January 4-14, 1988.
C.
Methodology For each of the 57 work requests selected by the NRC for review package was developed which included inspection, a the following information/ documentation:
o A complete copy of the work request.
o A copy of all material requests generated for the associated commercial grade material used, A copy of the purchase order (s) for the associated o
commercial grade materials.
o A copy of the warehouse stock issue record.
o A copy of the Receipt Inspection Data Report, if available.
t l
L Page A.2.1
1 Additional information was provided, including'the following:
o Equipment test reports.
o Manufacturer's specifications.
o Catalog descriptions.
o Manufacturer's Certificate of Conformance.
Each of the work request packages was then reviewed by the NRC.during their January 1988 inspection to assess the adequacy of commercial grade item dedication-practices historically emploved at Rancho Seco.
The work requests selected by the NRC documented the
- installation of over 239 commercial grade items.
These items were analyzed and found to be representative of the broad spectrum of the typical commercial grade items installed in Class I systems during the 1978 to 1986 time period.
Commercial grade items associated with these packages included:
Part Description Part Description Snubber Parts Relays O-Rings Pressure Transmitters Solenoids Contacts Breakers Motors Bailey Modules Relay Grounds Sensors Flanges l
Inverters Set Screws Limit Switches Terminal Strips Packing Tape Transistors Gaskets Cap Screws Filters Zine Nuts Sensing Lights Washers Tubing Materials Valve Actuators Couplings Seal Kits Hydrogen Catalyst Bed Valves Fuses Electro Wrap Bridging Connectors End Seals Splice Kits Conduit Rectifiers Integrated Circuits Meters Diodes Capacitors Switches Pressure Regulators Potentiometers 90 Degree Elbows Wire Terminal Lugs Transformers Page A.2.2
[
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Th'c.NRC evaluation concluded that the practices hi. urically employed by Rancho Seco in the use of commercial grade i? cms Wact satisfactory with the following exceptions:
o Work Requests 97391, 82120, 68932, 033177, and 112230 contained commercial grade item dedications based on
~
like-for-like acceptance that did not include a.
verification of design or manufacturing ~hanges that were made by the vendor, o-Work 1 Request 8C694 - No. certification existed on COMSIP catalyst for hydrogen monitors.
o Work Request 45631 - No test acceptance criteria was specified for a circuit breaker.
To evaluate these discrepancies, the Procurement Engineering Assessment team developed Instruction ERT-05, "Engineering Evaluation of Previously Installed Commercial Grade Items in Safety Related Systems".
This instruction delineated the process to be used in evaluating the impact of these CGI installations and, where necessary, dedicating the items for Class I use.
D.
Results 1.
WR 97391 - Ohmite Relay in the DCS Battery Charger This work request involved the replacement of a relay in the battery charger.
The vendor's bill of materials and recommended spare parts list specified an Ohmite Model No. DOX-46T, 3 pole / double throw relay for this application.
The current installed relay is an Ohmite Model No. DOX-480, 4 pole / double throw.
The dedication for this relay was based on a "like-for-like" determination.
No existing documentation which authorized the change in plant configuration from the originally supplied and qualified DOX-46T to the currently installed DOX-480 was found; thus, an NCR was written against this relay.
This resulted in a new commercial grade item dedication evaluation being performed.
Based on an analytical systems evaluation, chatter evaluation, and a similarity analysis between the two relays, it was determined that the DOX-480 was acceptable for this application.
The formal commercial grade item dedication has been completed which documents the adequacy of the DOX-480 relay and also
[
forms the basis for NCR closure, f
Page A.2.3
2.
.WR 821204-Wilmar Relay in the RCP Under Power Protection Cabinet in the RCS The review determined that the relay is no longer _
installed in the plant.
The review package'is complete.
3.
WR 68932 - GE Relay in the Reactor Sampling System The replacement relay was a commercially procured GE relay 70EF-4210 (CR2820A14AT-22).
The relay is currently being dedicated by General Electric via performing a similarity analysis between the relay currently installed and a similar relay installed in a motor control center that has undergone a qualification test.
4.
WR 33177 - Square D Relay in the SFAS H4SDB-00 Panel The review disclosed that the relay is a spare relay and not in use.
The.eview package is complete.
5.
WR 112230 - Square D Relay in-the SFAS.H4SDAS Panel The relay was procured commercial grade.
Square "D" has provided a Certificate of Conformance in accordance with their approved QA program indicating the design and material changes of the replacement relay as compared to the similar qualified relay.
This certificate forms the basis for a commercini grade item dedication currently being prepared in accordance with ERT-05.
6.
WR 88694 - COMSIP Certification of *ou Catelyst for Hydrogen Monitor Work Request 88694 replaced the existing catalyst bed in AE-53811 which is subject to the requirements of 10CFR50.49.
The work request package contained Purchase Order RS 55619 which procured replacement parts for the hydrogen analyzer as "commercial grade".
The inspector's concern centered on establishing that the replacement catalyst bed was the same material that was type tested.
The evaluation determined that the catalyst bed utilized in WR 88694 was procured under P.O.
RS69500 rather than RS55619, in response to IE Notice 84-22.
This was a QA Class I purchase which invoked 10CFR21.
It also required a Certificate of Compliance that the material supplied is equal in performance to those items originally supplied under contract 8354 which were qualified based on EA&T Test Report 1035-1.
Page A.2.4
m-The reason RS 55619 was originally included in the packr.ge was that the work request identified that a cell assembly for the hydrogen analyzer was ordered tar stock code 041560.
To alleviate any concern regardine the materini supplied under RS 55619, P.O.-RQ-88 s1 167.59 was initiated and the vendor has subsequently provided a Certificate of Conformance that all of the material supplied under P.O. RQ-88-03-16259 "is equal to or-botter than the material originally supplied and is qualified to the requirements of IEEE 323-1974 and IEEE 344-1975 as documented in EA&T Test Report No.
1035-1, Revision 2.
In addition, the material will not degrade the environmental qualification of the Hydrogen Analyzer."
The review package is complete.
7.
WR 45631 - Circuit Breaker The review has determined that the circuit breaker has been removed from service.
The review package is complete.
.1 j
Page A.2.5
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s ATTACHMENT 3
' SEISMIC EQUIPMENT QUALIFICATION (SEQ) OF REACTOR PROTECTION -
' QYSTEM (RPS) 'AND SAFETY FEATURES ACTUATION SYSTEM '(SFAS) RELAYS 2
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A iSEISHICTEQUIPMENT QUALIFICATION (SEQ) OF-' REACTOR: PROTECTION:
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if.SYSTEML(RPS)jAND' SAFETY 1 FEATURES.JACTUATION SYSTEM (SFAS)ERELAYS-J' s
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' /A. ' Oliective
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.Tolassessfthe.acceptabil'ity of commerci~al. grade replacement
. relays _usedfin the.RPS and SFAS..
B."
Scope-A111 relays'inDthe RPS and the.SFAS were reviewed'to identify chose relays which'have been modified or replaced since system instalLlation? LTo--accomplish ~ this, a complete work
'historyireview was! performed to identi'fy thoseirelays'that chad.been' replaced.or' modified.- ;TheLwork history. review.
disclosed'tha+-out of a total ~ofE1,114 relays in the:two sc systemsi(SMUD Engineering Report ERPT-E0316), 21 relays / modules had been replaced either as new or replacement parts.- -These' relays were then evaluated _to determine lwhether those-procured an commercial grade'had-been. properly dedicated for use in QA Class I, Seismic Applications.
.C.
Methodology.
Nuclear Engineering Department Report.ERPT-E0316 defines the methodologyJused to' identify the total number of relays in the RPS and SFAS.
In summary, the total number of relays in these1 systems is as-follows:
~
Module Reed Type l',041
' Square "D" 51 Westinghouse "S6" 21 Agastat E7012 1
Total 1,114 Equipment work histories were requested to identify those i
relays that had been modified or replaced.
The work history review disclosed that 21 relays had been installed as either new or replacement relays since installation of the systems.
- These relays were then reviewed in accordance with procedure l
ERT-05.
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4 LThe eva'l'uation: of[th'e* relayuudisc1' ~ sed t' hen fol? owingib 1
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- #1 DETERMI'NED
- '[REQOIRING;-
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- RELAYS.
- CLASS ~I NO' SAFETY: IMP.
CGIDEs s
1 1121655..
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.N/A.
N/As N/AM
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68281:
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- 68282
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'21; 13:
- 1 17 The,following summarizes the work performed and review
- status us.related'to each of'the above noted work requests:
~
t WR'121655L-P, isa21ey Control. Modules in' SFAS.H4SDA The work request involved-installing two' modules-per-ECN:A-5415?
The modules.have been procured Class-I.
The V'
review package.is currently'being prepared;in-accordance-with.ERT-05.
wR 121656f 4' Bailey Modules in SFAS H4SDA The work request. involved. testing with no replacements or g
modifications.
Thefreview: package is currently being prepared in accordance with ERT-05.
-WR 68281 - Bailey Module 3-5-1 in SFAS H4SDA-The work request involved replacing the Bailey module.
The module is a QA Class I purchase.
The review package is currently being prepared in accordance with the reGuirements 4
of instruction ERT-05.
Page A.3.2 r.
I.
. Bailey Module 3-5-1 in SFAS H4SDA The. work request repaired the Bailey module replac ed by WR 68281.and involves the replacement of-four relayr and changing out one, relay card and one circuit board.
The replacements were procured commercial grade and are qualified replacement parts for the Bailey module.
Bailey Meter Company nas provided Certificates of Compliance for-the replacement parts in accordance with their approved QA program.
These ceitificates' form the basis for a commercial
~
grade item dedication.
The review package and commercial grade item dedication evaluation are currently being prepared in accordance with ERT-05.
WR 60358 - Bailey Module 3-5-1 in SFAS H4SDA so The work request installed a module repaired under WR 68282.
The review package is currently being prepared in'accordance with ERT-05.
WR 60376 - One Card in Bailey Module 3-5-1 in SFAS H4SDA The work request repaired the card replaced under WR 68282.
-The review package is currently being prepared in accordance 5
with ERT-05.
WR 43021-43024 9 Relays in SFAS H4SDB-0, H4SDB-00, H4SDA-5 The work requests involve the installation of nine new relays per ECN A-2174.
The relays were procured commercial grade.
Square "D" has provided a Certificate of Compliance in accordance with their approved QA program, indicating the design and material changes of the replacement relay as compared to the similar qualified relay.
This cer tificate forms the basis for a commercial grade item dedication.
The review package and commercial grade item dedication evaluation have been completed in accordance with ERT-05.
WR 50473-Bailey Module 3-1-1 Replaced relay on card PC-2.
The replaced relay card was procured commercial grade and is a qualified replacement part for the Bailey module.
Bailey Meter Company has provided Certificates of Compliance for the replacement parts in accordance with their approved QA program.
These certificates form the basis for a commercial grade item dedication.
The review package and commercial grade item dedication evaluation are currently being prepared in accordance with ERT-05.
Page A.3.3
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WR 50469 - Bailey Mo'dule 3-1-l' Replaced relay card PC-2 with a card from a spare module.
The replaced relay card was procured commercial grade as-qualified replacement part for the Bailey module.
Bailey Meter Company.has provided Certificates of Compliance for the replacement' parts in accordance with their approved QA program.
These certificates form the basis for a commercial grade item dedication.
The review package and commercial grade item dedication evaluation are currently being
~
prepared in accordance with ERT-05.
WR 33177 - Square D Relay in the SFAS-H4SDB-00 Panel.
The review disclosed that the relay is a spare relay and not in use.
The-review package is complete.
WR 112230 - Square D Relay in the SFAS H4SDAS Panel The relay was procured commercial grade.
Square "D" has provided a Certificate of Conformance in accordance with their approved QA program ind*cating the design and material changes of the replacement relay as compared to the similar qualified relay.
This certificate forms the basis for a commercial grade item dedication currently being prepared in accordance with ERT-05.
E.
Conclusions Based on the review of all 1,114 relays in the RPS and SFAS and an assessment of the replacement relays, we have concluded that the use of commercial grade replacement relays is acceptable and does not affect system safety.
l l
Page A.3.4 1
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6 I
ATTACIIMENT 4 ENVIRONMENTAL qijszyp, d
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n PIECE-PART ENVIRONMENTAL QUALIFICATION (EQ)
A.
Objective To verify acceptability of replacement parts, procured as commercial grade, and accepted based-on a like-for-like evaluation for various EQ applications.
B.
Scope The piece-part evaluation applies to all EQ replacement parts procured as commercial grade and installed since November 30, 1985.
A work history review was performed on all EQ equipment to identify all work requests written against that equipment since November 30, 1985.
The review indicated that for the 484 EQ equipment tag numbers, 1,085 work requests have been issued for which the field work has been completed.
Of these work requests, an engineering review identified 739 work-requests which may involve parts replacement or modifications.
This represents the group of work requests that an evaluation on the adequacy of Commercial Grade Items in EQ applications has been or is being. performed.
Each of the 739 work requests was categorized into one of eleven categories representing different types of' equipment.
From the group of work requests in each of the 11 categories, the evaluation team selected a representative sample of each to assess in accordance with the requirements of instruction ERT-05.
C.
Methodology The EQ Master List, as defined by Engineering Report ERPT-E0177, was utilized to define the entire population of equipment tag numbers on the 10CFR50.49 equipment list.
The list of tag numbers was subdivided into the following categories:
Category EQ Equipment No.
Description Tag Numbers 1
Motor Operated Valves 99 2
Solenoid Valves 86 3
Transmitter 90 4
Limit Switches 48 page A.4.1
ry o.
4 D
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g Q'
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iCategoryf,"..'
"EQ: Equipment-i,. ^
No.
>' ; Description ~
'Tagi-Numbers. 1 p %,
~
V
i.
60.
5' LMiscellaneous'
.u-
.c
, ~
e i.n,
' Transducers..
4 l~
Transfer' Switches'
' Cont'rol Switches-
'HeatLTracingi.
~
~~
-Pressure Switches L'
' ~
- PORV-Radiation Monitors s
[RTD/ Thermocouple.
6-
. Hydrogen, Analyzer-
- 6
"['
.7 Cables; Splices',.
- 22
'l Terminal Blocks 8-Feedthroughs/Elec.
-24 Penetration
-9
. Motors 27.
10~
Hydrogen R'ecombiners; 8
- 11 Acoustic Monitors 24 Jn 484 The
- work history was reviewed to identify-all modification or maintenance work.which has,been' performed on the equipment since November 30,.,1985..'The purpose was to fl i
~
identify a l cases 1wherc spare parts were'installedfin EQ.
applications and to evaluate..theirfimpact on the qualified status.of the equipment..Those work requests:that involved replacement of items were subjected to an' evaluation per the requirements of ERT-05.
4.
The' ev~aluation involved the assembly of work request evaluation. packages that included the following information/ documentation' as applicabic:
.o A complete copy of the work request.
o A' copy of the material request generated for all material used in the work performed.
o A_ copy of-the purchase order (s) for the associated materials.
o A copy of the warehouse stock issue record.
r Page A.4.2 v
,1-.
Ib.
' n-Additional-information. if available, included the following:
o. Equipment Test Reports o
Manufacturers Specifications o
Catalog Descriptions-o Manufacturer's Certificate of Compliance.
'D.
Results
'To date, 186 work requests have been reviewed with 155'
. currently in the approval cycle.
Of~the 155, 20 commercial grade item dedication evaluations have been or are in the process of being generated.
A summary of the parts
. associated with the 155 work requests in the approval cycle is as follows:
Work Parts Parts Required Category Reauests Parts Q1 CG Replacement MOVs 33 21 10 11 0
Solenoids 23 40 36 4
0 Transmitters 25 44 21 23 0
Limit Switches 4
0 0
0 0
Miscellaneous 30 29 28 1
0 Hydrogen Analyzers 15 21 2
19 2 4:00kil,Vire)
Cable, Splices, 0
0 0
0 0
Terminal Blocks Feedthrough 3
73 0
73 0
Penetrations Motors 7
3 2
1 0
H Recombiners 7
8 0
8 0
2 Acoustic Monitors 8
14 0
14 0
Totals 155 253 99 154 2
i Page A.4.3
-s.
e
-The' review to date.has resulted in the generation of three NCRs.
These.are as follows:
NCR 7772 - ASCO Coil in the Hydrogen Monitor Solenoid The hydrogen monitor panel H-4HMB currently-contains a solenoid valve with an incorrect coil.
The coil is not.the high temperature. Class H coil which has been qualified by the vendor in: EA&T Test Report -1035-1.
As a result, the coil.in question is being replaced.
Investigation of this condition and its associated root cause determined this'to be an isolated occurrence in-that the stock identification number for the coil applies to coils used in the-hydrogen monitors only and the stock code inadvertently omitted the designation "THT" as a prefix to the manufacturer's coil number.
Further review of all solenoid valves in EQ applications indicates no other occurrence of this condition, nor has there been any evidence of incorrect stock card designations in any of the other 154 work requests in the approval process.
NCR 7775 - Accelerometers and Cables in the MSS Acoustic Monitors The acoustic monitors associated with the atmospheric dump-valves for position indication in the Main Steam System were repaired by replacing the accelerometers and associated
' cabling with Class II items.
Class II items were used because the equipment is in faat on a Class II system; however, the equipment was placed on the 10CFR50.49 Master List based on Reg Guide 1.97 Category 2 qualification requirements.
The replacement of these items with unqualified Class II items caused the qualified status of the equipment to be indeterminate.
An assessment of the need to include these accelerometers in the 50.49 list has determined that they can be removed from the list because they were installed in response to NUREG 0737 and SMUD does not consider them to be a Reg Guide 1.97 Category 2 variable.
An assessment of the root cause for this condition indicates that the condition occurred as a result of the purchase, receipt and installation of the items as Class II.
This was consistent with the QA classification of the equipment.
A review of all Class II EQ identified items on the Master Equipment List and their associated work histories has been accomplished and no other instances of using commercial grade parts have been identified.
Further, an investigation of all accelerometers and cabling associated with the Master t
l Equipment List and the corresponding stock issue has been performed to assure that installation in Class I applications has not occurred.
This investigation has l
determined that no installations of non-Class I l
accelerometers and associated cabling in Class I applications have been performed.
l Page A.4.4 t
4
't NCR S-7788
' Wiring in the Hydrogen Monitor Cabinet ~ Heater
-The containment hydrogen monitor local panel (H-4HMA) contains power wiring to the. heater elements that is not in conformance with the vendor drawings.
The associated work request-replaced the heater wires with #14 SIS nuclear grade-wiring.
The inspection of the work performed on the work-request was accomplished using vendor (COMSIP) Drawing.
No. 02362 Sheet 4 of 4 (M19.87-11).
This drawing does not specify wire type or size but does reference other vendor drawings.
The vendor drawing that provides a description of the wiring requirements-is M19.87-4.
It does not specifically designate that the correct wire for the heater circuits inside the hot box assembly is #16 AWG silicone insulated wiring.
It does specify that #12 AWG EPR/hypalon be used for power wiring.
Based on a walkdown of hydrogen monitor H4HMA, the wiring to the heaters from TS1 to HTR 1 (Ref. M19.87-9 and'11) has been replaced with #14 AWG Rockbestos Firewall SIS 600V wiring which is rated at 90 C and is qualified to the requirements of IEEE-383.
The manufacturer of the hydrogen analyzer (COMSIP, Inc.) has informed SMUD that all wiring located in.the heated sample compartment (hot box) of-the containment monitoring system installed in Rancho Seco must be 16 gauge BIW silicone wire (the originally qualified
- wiring).
During the walkdown it was further observed that the insulation on the Rockbestos Firewall SIS inside the hot box assembly had deteriorated due to over heating.
This wiring is not designed to withstand coatinuous exposure to the temperature environment in the hot box assembly (285 F).
As a rebult of this condition, an NCR was generated and dispositioned to replace the wire.
Our root cause analysis concludes that this condition is isolated to the specific vendor drawing being ambiguous regarding the lack of design information for the wiring rcoted inside the hot bo.y assembly.
Improper wiring was utilized because the information was not available to aid in the selection and inspection of the wiring replaced under Work Request No.
117355.
This occurrence is considered to be limited to the COMSIP hydrogen analyzers.
To assure that this condition did not exist in the other analyzer (H4HMB), a review of work history and a walkdown was performed.
These reviews concluded that no wiring changes have been performed and the proper wire is installed.
Page A.4.5
-- t E.
Conclusions Based on the results of the 186-work requests reviewed to
- date and the disposition of the three associated NCRs, it has been concluded that the use of_ commercial grade items has not degraded plant safety and that the environmental qualification of equipment subject.to 10CFR50.49 has been maintained.
Page A.4.6 L
i y
(
ATTACllMENT 5 ENHANCEMENT OF EXISTING PROCEDURES s
s:
9 0
ENHANCEMENT OF EXISTING PROCEDURES A.
Objective The_ procedure enhancement effort was: undertaken to clarify and strengthen the controls for procurement-related procedures.
B.
Scope The~ enhancements were made to clarify and strengthen the controls for Class I, Procurement Level 3 activities.
This included reissue of.the procurement level control procedure in a' plant level procedo-- -nd the addition of supplemental guidance for engir.eering evaluation of Level 3 procurement items.
In addition, other procurement-related procedures were reviewed to resolve noted discrepancies such as incorrect references.
C.
Summary of Revisions The foilowing is a brief synopsis of revisions made to the Material / Procurement Control procedures.
Titles for these procedures are provided on page A.5.5.
MMP-0022 MMP-0023 Updated Reference Section.
I Updated Format to latest requirements.
MMP-0024 MMP-0025 MMP-0028 MMP-0026 (Four Level Procurement System) - procedure has been canceled and replaced by RSAP-0408 (Expanded).
RSAP-0401 Updated Reference Section.
I Updated Format to latest requirements.
RSAP-0701 RSAP-0704 RSAP-0403 Issued PCN to update Reference Section.
RSAP-0405 Updated Reference Section and Format.
Replaced Attachment 4 to reflect latest revision of a "typical" RIDR.
Page A.5.1 J
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JMMPIO021 -
JUpdat'ed ReferenceiSectfSri andL Format.;;. _
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S Y '";
(.
RevisediAttachmentJ3 Jatandard; clauses):
y V
'.-d tPage:3Eoff10jto:revi's'nthe.foptionJ thatTa;._
~
=
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~ '
supplier couldt.provideTan? item.as Commercial' iGradeTon alProcurementiLev'el icorf2: Purchase,..
t
" ye. J 2 Order.LfIn doingLthis,sthe supplierlwill:be~
S "'
- requiredito document their: request';on1thejSDR)
~
c therebylo'btaining;EngineeringEevaluation, Y:7
/
_priornto; shipment.-
l
.RSAP'-0706:
'Added definition for ai"GenericiDedication".-
L g
, ' Deleted? separate 1referenceJto.EQ/ SEQ! items:-
these: items have.theJsame requirements as-QAL i
i
- I
'ClassNILitems.: ' Deleted allLGeneric Items:
1
.which were-listed'asunot requiring. dedication -
these: items will n'ow-be dedicated on'a
-Commercial Material'Evaluationj(CME)Las.a "Generic ' Dedication'I'.
.RSAP-0808
- Under preparation;for1SIDR..
s
~
(
Shall1 identify any; criteria est'ablishediby
. Nuclear Engineering'duringithefprocurement
~
review-process.
NEAP 4202 Updated the: Reference.Section and Format.
RemovedLthe. CME Review methodo15gylwhich;is.
Lbeing addedJinto NEAP-4205.'
~ Updated _thel Reference Section andlFormat.
NEAP'4205
-The-following changes were madei-A Quality Related Item.Evaluat'i~on review-
.o was added to a'ddress the definition of characteristicsTimportant to function for items.being purchased through
~
Procurement Level 4.
L This : strengthens the method by which,the' critical <
characteristics are defined / verified-prior to procurement.
o Eliminated like-for-like verification as i.
a means to accept a commercial grade item.
Critical characteristics for identical replacements are verified.
Page A.5.2 t..-_
-v ty RSAP-0404' This procedure replaces MMP-0026 and was expanded to include:
11.
Expanded scope'to clarify the-type of equipment / components / items applied to the.Four Level Procurement System.
2.
Added. Definitions for C of-C, Services, Surveillances, Test, Source Inspection and Commercial Grade Item.
3.
Added Responsibility Section to c1'early delineate responsibilities to Procurement Engineering, Quality Engineering and Nuclear Engineering with respect to reviewing, evaluating and approving procurement documents.
4.
Revised description of Procurement Level 3 (Verification Method) to clarify type of procurement this classification is applicable to, the methods by which the items can be accepted, and the approvals required for this type of purchase.
5.
Added two new attachments to identify review responsibility and specific procedures to be implemented for each review responsibility.
Added a table to illustrate examples of each type of purchase, required approvals, method of acceptance and applicable procedures governing each review.
o Addressed the transmittal of supplemental inspection and/or testing requirements and acceptance criteria to the Planning Department for incorporation into applicable work request (s).
This applies to post-receipt or post-installation testing, QC Hold / Witness points in vork requests to verify acceptability of an item.
QAIP-0701 Updated procedure to clarify the initial supplier approval process.
The paragraph allowing unrestricted placement on the ASL immediately after a successful audit has been eliminated.
A reference has been added to identify NRC Inspection Report 98-02.
Page A.5.3
a 1
- D ~.
Training'of Personnel A. comprehensive training program is un' der' development for Engineering'and Material Control / Procurement. personnel.
The program. covers Procurement and Engineering evaluations, particularly Commercial Grade Item Dedication and the Class.I,=
Level-3 purchase process.
It'provides an overview of the
~ !
four level procurement system.
The-Technical Staff Training group of the' Nuclear Training Department is providing-assistance for the development of training materials, guidance.for. proper. formats and training processes, coordination of time and training location and process of the attendance records through the system consistent with existing Training Department procedures.
E.
Long Term Enhancements 1.
Develop Procedure MMAP-0003 (NUCLEIS).
2.
Develop Procedure MMP-0027, Inventory Control'and Stock Level Maintenance.
3.
Develop Commodity List (Ref RSAP-0405).
4.
Develop Maintenance Procedure to interface with MMP-0026 (In-Storage Maintenance).
5.
Consolidate RSAPs 0405 and 0706 (Commercial Grade Dedication Program).
6.
Revise MMP-0021 to include 1.ngic. Chart for Determining Procurement Level.
7.
Consider the addition of a five level system with a separate generic material classification.
Page A.5.4 L
s
.c TITLES OF REVISED PROCEDURES RSAP-0401 PREPARATION AND' PROCESSING OF PURCHASE REQUISITIONS RSAP-0403 PROCESSING OF BLANKET PURCilASE ORDER AGREEMENTS c
RSAP-0404 CONTRACTING RSAP-0405 QUALITY-RELATED ITEM REVIEW-RSAP-0701 ISSUE AND RETURN OF ITEMS TO STORAGE RSAP-0704 STOCK RECLASSIFICATION REQUIREMENTS EVALUATION RSAP-0706 DEDICATION OF COMMERCIAL GRADE ITEMS' RSAP-0808 QC INSPECTION NEAP-4202 PROCUREMENT DOCUMENT REVIEW NEAP-4205 COMMERCIAL GRADE ITEM DEDICATION EVALUATION MMP-0021 TECHNICAL AND QUALITY DETERMINATION FOR PROCUREMENT DOCUMENTS MMP-0022 PROCUREMENT MMP-0023 RECEIPT OF ITEMS MMP-0024 IDENTIFICATION AND MARKING OF ITEMS MMP-0025 PRESERVATION, STORAGE AND MAINTENANCE OF ITEMS IN STORAGE MMP-0026 FOUR LEVEL PROCUREMENT SYSTEM MMP-0028 RECEIVING, STORAGE, IIANDLING AND ISSUANCE OF HAZARDOUS MATERIAL QAIP-0701 APPROVED SUPPLIER LIST Page A.5.5
k A
1 k
i ATTACllMENT 6 GREEN TAG PROGRAM
-GREEN' TAU PROGRAM A.
Objective The objective'of the'"green tag" program is to provide
. assurance that' Class I items which'are available-from the warehouse (s).for plant installation in Class-I systems have the required procurement and inspection documentation.
The scope and methods for implementing the program are described in Instruction ERT-06, "Sample Evaluation of Class I Warehouse Stock Currently Available for Issue".
B.
Scope
'In order to provide the assurance that "acceptable" Class I items.in the warehouse have the required documentation, a program to survey.such items was initiated.
The survey consists of approximately 100 items presently in the warehouse which were procured prior to implementation of.
the current' procurement program (1987), are tagged as Class I, and are available for issue.
C.-
Methodology In order to provide a representative survey of items, as well as satisfy selection criteria consistent with existing procurement guidelines and/or instructions, the following methods were utilized:
- a '.
Walkdown of the warehouse (s) were performed to physically locate and examine existing stock items which satisfied the following criteria:
Items with "green tags" casignated as Class I, non-commercial grade.
All required "green tag" information necessary for issuance from the warehouse (s) was completed.
"Green tags" were not missing or mutilated.
b.
To ensure that a representative group vas selected, items were chosen from over 20 vendors, purchase years between 1974 and 1986, and various plant systems.
page A.6.1 f
3 c.
An' effort was alsoLmade to:
- 1) provide a--group consisting of approximately. 70% electrical items and 30% mechanical items, and 2) minimize the number of multiple.-items procured ~ under :the same purchase order even if the items were of different stock code numbers.
. Items "green tagged" but identified as commercial grade have not.been:' included in.the survey because they are being addressed by a' separate _ program.
Under this program all-commercial grade items are required to be reverified prior to issuance;from'the warehouse.for.a-Class I application.
After identification of "acceptable" items for the survey, individual documentation packages ~were prepared _for each of the items.
All packages were reviewed by Procurement Engineering and Quality Engineering.
If necessary, packages were reviewed by Nuclear Engineering for appropriate EQ/ SEQ documentation.
NCRs were initiated:to identify items for which adequate documentation was not available.
Instruction ERT-06 details the review process.
In order to ensure that the survey program and the review of documentation packages have been conducted in a manner consistent with the referenced instruction, the Quality Assurance _ Surveillance Group performed a surveillance of the activities.
The results of these activities were documented and appropriate corrective action is being implemented.
With the exception of the' issue relating to implementation of 10CFR21, no significant items have been noted.
D.
Results It became evident after initiation of the program that it would be difficult to obtain a group of 100 items satisfying the selection criteria.
At present, 74 items have been identified which satisfy the specified criteria.
Of these items, 50 documentation packages have been reviewed and are considered satisfactory.
The remaining packages are currently either being reviewed by the disciplines previously discussed or the required documentation is being researched and assembled by Procurement.
Of the various items identified, 44 are electrical items and 30 are mechanical items.
This represents approximately 60% electrical and 40% mechanical items.
Since the surveyed group represents such a high percentage of the total items available for issue which satisfy the selection criteria, this is considered acceptable and consistent with the desired ratio of 70 percent electrical and 30 percent mechanical items.
Page A.6.2
Of 54 packages which have been evaluated, two items which had been chosen from the walkdown had inadequate documentation.
NCRs were issued for these.
Both items have been evaluated by Nuclear Engineering and have been dispositioned as acceptable.
The first NCR was for a control switch' installed in a Class IE'switchgear for which no C of C was available.
Nuclear Engineering reviewed the available documentation and determined that the control switch was a like-for-like replacement and that qualification documentation was available for similar items and was applicable to this item.
The second NCR was issued for a 1" Pipe Tee from a vendor for which it could not be determined if this vendor (Ladish) was on the Approved Suppliers List in 1975.
Nu list is currently available for vendors in 1975 or 1976.
This item was procured to ASME III Class I and was appropriately receipt inspected.
Since it could not be shown that the vendor was authorized as an approved supplier, a search was made for the original manufacturer's Certified Material Test Reports.
Traceability was available for this item through the heat numbar and purchase order to the original material supplier.
All necessary documentation was available for this item.
For this item it could not be demonstrated with existing documentation that Ladish (Cynthiana) was authorized to distribute material certified to ASME Section III.
At the time of manufacture this vendor plant did not hold an ASME certificate nor could it be demonstrated that SMUD had audited the Ladish Quality Program.
It could be demonstrated that Bechtel had performed surveys and audits of this plant for the time period in question.
These audits confirmed that Ladish had a Quality program in place which met the requirements of ASME and which was acceptable.
This acceptance was through Bechtel's N-Stamp.
This N-Stamp, however, was not for the Rancho Seco plant.
Reasonable assurance is provided that the certified material test reports from Ladish were representative of the stock I
material in that Bechtel was the engineer and constructor of Rancho Seco and their Quality Assurance program was implemented.
That rame program was used to certify Ladish to ASME Section III requirements.
Due to the material traceability to the original materint supplier as an ASME N-Stamp holder and the audits performed i
by Bechtel on the Ladish plant, reasonable assurance is provided that the material as received on site and installed in the plant meets the intent of the ASME code and that the i
material is acceptable for use tb Class I systems.
i l
page A.6.3 l-
During the course of evaluating the green tag packages it was identified that a number of purchase orders (11 of the packages reviewed) failed to impose 10CFR21 reporting requirements on the vendor.
Since the eleven packages were for Class I equipment, 10CF221 requirements should have been imposed.
- The approach taken by the Procurement Engineering Assessment Team has been to send a letter to all suppliers of Class I equipment from.1978 to the present.
This letter informs them.of the possible omission of 10CFR21 requirements and requests a confirmation that even though the purchase order may not have specifically imposed 10CFR21 on the vendor, the
- reporting requirements were nevertheless self-imposed by the equipment supplier or imposed by other customers.
Distribution of the letter will not be limited to the 11 purchase orders discovered during the green tag program, but is being sent to all suppliers of Class I equipment from 1978 to the present.
Since these suppliers were at some time on the approved suppliers list, they were required to have a 10CFR Appendix B Quality Assurance program and thus were subject to 10CFR21 for any equipment intended for nuclear applications.
It is with this philosophy in mind that the assessment team decided to ask e.ch supplier to confirm that indeed 10CFR21 was applicable to the purchased equipment.
For those cases in which a supplier is no longer in business, a review of this supplier's sales to ather utilities will be performed.
When a utility that also received similar equipment from the supplier is identified, it will be determined if 10CFR21 wan imposed.
The rationale is that if the equipment supplied to another utility was per 10CFR21, then the equipment supplied to Rancho Seco was also subject to 10CFR21.
Parallel to this effort, the assessment team has also undertaken the task of reviewing 10CFR21 publications, bulletins, notices, etc.,
for applicability to Rancho Seco equipment.
This effort is presently under way.
By covering all previous or presently approved suppliers and reviewing 10CFR21 publications, compliance to 10CFR21 can be assured.
Those cases that might require fur ther action will be addressed on a case by case basis.
i I
I l
page A.6.4
E.
-Conclusions As the result of the warehouse walkdowns conducted for this survey, it is estimated that over 50% of the Class I items which could.be issued to Class I applications were reviewed.
~Although the group size is smaller than. expected, it represents a larger percentage of the items available for issue,.thus providing increased assurance of the acceptability of the items.availabic.
Two items had NCRs issued for documentation deficiencies.
These have been evaluated by Nuclear Engineering and dispositioned as acceptable.
Over 70% of the survey items have been evaluated and found acceptable.
The remaining items are still in the review process.
With the. exception of the issue relating to implementation of 10CFR21, no significant items have been noted.
We believe that more than adequate assurance has been provided to demonstrate that Class I warehouse items available for issue have the required procurement and inspection documentation.
The programmatic deficiency with regard to imposing 10CFR21 on Class I vendors was identified during the review Trocess.
This deficiency is being addressed programmetically to ensure that the intent of 10CFR21 is met.
l i
Page A.6.5
7 9
4 1
i.
ATTACIIMENT 7-RESOLU? ION OF NRC-IDENTIF1ED DISCREPANCIES I
e 1
l l
l I
9 RESOLUTION OF NRC-IDENTIFIED DISCREPANCIES A.
Bergen-Patterson Snubbers Problem Description During the initial inspection visit (Jan 4-14,_1988), the NRC noted that some old QA Class I purchase orders to Bergen-Patterson did not contain the required 10CFR21 applicability statement.
The Inspection Team requested that SMUD obtain a written statement on Part 21 applicability from Bergen-Patterson.
SMUD agreed to do so.
Discussion with Bergen-Patterson indicated that they recognized the applicability of 10CFR21 in spite of our omission.
The extent of the problem was established by researching the Rancho Seco purchase order history files.
A list of suspect purchase order numbers was compiled.
Bergen-Patterson indicated that their records retrieval system would require the Bergen-Patterson Job Number if expeditious action was desired.
It was therefore necessary to search the supporting documentation for each suspect purchase order to determine the Bergen-Patterson Job Numbers.
This hcs been completed.
The resultant list of Rancho Seco Purchase Orders cross indexed to Bergen-Patterson 'ob Numbers has been provided to Bergen-Fatterson for their action.
Corrective Actions Bergen-Patterson has agreed that their own Quality Assurance Program would have applied Part 21 requirements to all Quality Class I purchases received from SMUD.
They have agreed tc retrieve applicable documerts but, are unwilling to commit to a firm completion date.
This reluctance is based upon the fact that they have moved most of the records originally stored in their facility in Woburn, Mass.
They are not sure (yet), which location has the necessary documents.
A confirmatory Purchase Order (PRW No. 2a?57) to Bergen-Patterson was sent to cover this document extraction effort.
Page A.7.1
a B.
NRW Cable Qualification Problem Description Power cable-(5kV) was procured Class I, Procurement Level 3 from NSSS/DIVESCO for the Nuclear Raw Water-System in November 1987 on the basis that testing was to be performed by an, independent laboratory following receipt.
An NCR (S-7220) was initiated -to conditionally release the cable for installation pendinr4 receipt of the test data. -Nuclear Engineering reviewed +he NCR and dispositioned the cable as "accept" based on dreamentation from an unapproved supplier and qualification > ests from a previous procurement of a similar cable.
The District's review of this issue identified several generic concerne r.ated to Procurement Level 3 practices as well as a
-e.ific purchase of the cable.
Cornective Actions
- As e result of the concern regarding the qualification of the cable installed under Engineering Change Notice R-2276, NCR S-7631 and ODR 88-0032 were generated to resolve this issue.
A purchase order (RQ-88-03-16267) was initiated to
- test samples of.the NRW cable supplied by NSSS/DIVESCO to-the requirements of Section 2.5 of IEEE-383 (1974).
The cable is considered "operable" based on the results of the post installation function tests (MEGGAR) and successful completion of the flame tests.
This testing will be supp?emented with additional testing to establish a qualified life of the installed cable, per the requirements of IEEE-383.
C.
No Procedures for Disposition of Damaged or Dropped Materials Problem Description No procedures or instructions exist to address damaged or i
dropped materials.
Corrective Actions Materials Management Desk Instruction, MMDI-0043 "Handling Damaged Material" has been issued.
This instruction describes the specific actions to be taken in the event an i
item is accidentally damaged while it is being inspected, carried, transported, or stored.
l-l l
Page A.7.2
' D.-
Bin 51E08 - Class I Bolts Located in Class II Bin Problem Description
.All~ Class I bolting was to have been relocated to Storage Row ~4-in order to achieve complete ph3sical segregation of Class I and Class II bolting.
The A-325 bolts. located in bin 51E08 were overlooked during that relocati'on.
Corrective Actions The bolts were relocated to Row 4 immediately after the NRC inspector brought this to the attention of management.
These bolts, while in bin 51E08 in the' designated Class II area,.were properly classified as Class I and were.
identified by the appropriate green tag.
E.
Potential Co-mingling of Class I/ Level 4 Cap Screws Problem Description An NRC inspector identified a case where two different size cap screws were located in the same bin.
The cap screws were of the same material characteristica.
One size was 1-1/2 inch length and the other was 1-1/4 inch length.
A plastic-bag of five each 1-1/4 inch capscrews was removed in the presence of the inspector.
Corrective Actions The inspector found no co-mingling of nuts.
The inspector did address the potential that co-mingling could occur when boxes are left open.
One box was relocated to a different row.within the bin area and instructions have been issuen to Materials llandlers to re-scal containers after partial issue.
Both the partial issue and the re-scaling of the containers are witnessed by Quality Control Inspectors.
It should be noted that SMUD is currently evaluating the generic issue of potential co-mingling as part of tne response to IE Bulletin 87-02.
Refer to SMUD letter GCA 88-030 dated January 20, 1988.
Page A.7.3
e' s
F.
-Stock Code'8929 - Class II Bolts Referenced to Class-I Work Recuest' Problem' Description Class-I WR.126201' dated December 31, 1986.was isuued to perform the-inspection of pipe restraint No.
1G-2^1D -16.
A review of the pipe restraint drawing reveals that t'.
only fastening is'a "U" bolt.- Stock Code 008929'is a 3/4" x 1-
.3/4" fastener.
Interviews with the Modification Department field' engineers revealed that in order to inspect.the pipe restraint,. temporary scaffolding was required.
Fifty each-of Stock Code 008929 were withdrawn to support the. erection of the scaffolding..After inspection of'the hanger, the scaffolding was disassembled and returned.to the carpenter shop holding area.
The withdrawal request for Stock Code 008920 referred to the Class I work request an a convenience to field personnel.in order to accumulate all charges (direct and distribute) under une work request.
Corrective Actions It should be noted that current procedures would not allow
.the issuance of a Class II or lower item to a Class I work request.
Field personnel are currently required.to initiate a separate WR for the scaffolding erection.
G.-
Generic CGIDs problem Description In completing the generic CGIDs, cases have occurred in which the requirements of the CGID are more stringent than those to which the material was initially procured and received.
Corrective Actions The District is developing a retrofit action plan to upgrade materials in warehouse stock to the requirements of the newly approved generic CGIDs.
Generic CommerciL1 Grade Item Dedications have been prepared for numerous parts which are frequently used in the plant and for whi
the requirements for each application is simple and identitiable, (e.g.
grout, Unistrut products, unshielded terminal lugs, valve packing, and gaskets).
For these items, the requirements of the generic CGID will be implemented as each shipment is received.
No additional dedication activity will occur when the parts are issued from the warehouse and installed.
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II. - CGID Evaluations Since 9/87 Program
. Problem' Description-SMUD had previously established a program and is in the process of.reverifying all commercial grade. items which are warehouse stock, prior to issue or use in the plant.- This is'
- being done.in accordance with ERT-05.
Items previously.
reviewed as:part of this stock material' reverification for commercial grade items had been verified using the old like-for-like evaluation methodology which was determined to be inadequate.. CGID 4927 on an Agastat relay was identified by
'the NRC as tut example of an inadequate reverification.
Corrective Actions e
1)-
CGID-4297 - Agastat Relay The review-determined that the Agastat 7032 relay installed in the undervoltage protection system could not meet the specified pickup and drop out timing specifications.
The relay was subsequently replaced by another commercially procured Agastat 7032 relay.
This type of relay was the subject:of IL Notice.87-66 recently issued by the'NRC, 7
Initial efforts to dedicate this relay were unsuccessful because testing documentation to demonstrate seismic acceptability or to establish design and manufacturing similarity with previously tested relays could not be located.
The relay will therefore be removed and seismically tested at Wyle Laboratories.
To maintain system operability, 2 single-headed Agastat l
nuclear grade relays (E7011 and E7022) will be installed in place of the removed double-headed relay).
This will be elone in accordance with an Engineering Change Notice.
The results of the test on the removed relay along with ongoing efforts to address the recently issued IE Notice 87-66 will determine the need for additional actions associated with' r
generic implications.
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CGID Re-evaluation CGID evaluations made in acccrdanceiwith the old process thall be re-evaluated in accordance with ERT-05 and NEAP-4205.- This process is currently under way and is scheduled-for completiori by April 15, 1988.. Currently, 239 CGIDE packages-have been identified for items previously dedicated using the like-for-like acceptance methodology.
Engineering has completed.or is in the process of-completing their evaluations of 24 CGIDEs per the requi~rements of.ERT-05.
Commercial grade items associated with these 24 CGIDEs include:
o-Snubber Seal Kits o
Filter Assemblies o
Snubber Piston Rings o
Washers
-o Limitorque Gasket and o
0-Rings Sect Kit o
Pipe Clamp-o Fuel Storage Building o
Fittings Crane Hook o
Tees o
Resistors o
Valve Handwheel o
GE Circuit Dreaker o
Valve Packing Parts o
Miter Gear o
Crankcase Heaters o
Others The results of the re-evaltation to date indicate that in every case, proper dedicat,ons can be accomplished.
I.
Vendor Audit Program Problem Lescription During the initial inspection visit, the NRC noted that the system for approving suppliers would allow purchases to be made without a "timely" verification of acceptable program implementation.
Rancho Seco's prescribed process for initial supplier approval is based on the review of the supplier's quality assurance mrogram against the pertinent criteric of 10CFR50 Appendix s.
During this ceview process, an implementation audit checklist is also prepared.
However, the procedure
' Paragraph'5.1.1.4 of QAlp-0701) allows the supplier to be placed on the ASL immediately after the satisfactory program evaluation.
This process does not ensure that a program implementation evaluation (audit or survey) will occur prior to or during the "first significant" procurement activity.
SMUD agreed to strengthen and clarify this process.
page A.7.6 l
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Corrective Actions A procedure change has been initiated to clarify the questioned portion of the initial supplier approval process.
The paragraph allowing unrestricted placement on the ASL immediately after a satisfactory program e.udit has been eliminated.
A clear reference to NRC Inspection Report 88-02 has been placed in the "Commitment Documents" section of QAIp-0701.
This will preclude inadvertent restoration of the questioned process.
The procedure revision became effective during the week of February 15, 1988.
The files far each supplier on the ASL are being reviewed.
An updated ASL was published during the week of February 15, 1988.
A requirement for formal Source Inspection of each procurement shall be imposed against any listed suppliers for which we do not have "current" objective evidence of satisfactory program implementation evaluation.
This requirement shall be stated as_the first line of the ASL product description section to ensure visibility to the buyers.
The stated corrective actions should adequately resolve the concerns expressed by the Inspection Team.
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