ML20154N895

Insp Rept 50-344/88-39 on 880808-12.One Unresolved Item on Purchase & Use of Commercial Grade Items in safety-related Sys Identified.Major Areas Inspected:Commercial Grade Procurement & Pipe Support Design Verification

ML20154N895
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/31/1988
From:	Richards S, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20154N873	List: ML20154N870 ML20154N895
References
50-344-88-39, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8809300036
Download: ML20154N895 (6)

See also: IR 05000344/1988039

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No: 50-344/88-39 l

Docket No: 50-344

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License No: NPF-1 l

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Licensee: Portland General Electric Company

121 S.W. Salmon Street {

Portland, Oregon 97204

Facility Name: Trojan Nuclear Plant

Inspection conducted: August 8-12, 88

Inspector: MMM @ ///

W. ner,' Reactor nspector Dat( S Wne~

Approved: N MS , 8 IA

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chards, Chi

eering Sectio iKte41gned

Sumary:

Inspection During the Period of August 8-12, 1988

(Report 50-344/88-39)

( Areas Inspected: Routine, unannounced inspection by regional based inspectors

of commercial grade procurement and pipe support design verification. NRC

Inspection Procedures 30703, and 38703 were covered during this inspection.

Results: One unresolved item on the purchase and use of commercial grade

items in safety-related systems was identified.

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DETAILS

1. Persons Contacted

• C. A. Olsstead, General Manager

• J. D. Reid, Manager, Plant Services

• L. Erickson, Manager, Nuclear QA Department

• C. Brown, QA Operati.)ns Manager

• 0. Nordstrom, Compliance Engineer

• D. Ferrell, Matertul Quality Supervisor

• R. P. Sheppard, QA Engineer

• J. Lentsch, Manager, Chemistry and Radiological Control

"J. Anderson, Materials Nanager

"R. Benett, Maintenance fianager

• B. Susee, Outage Manager

B. R. Turbitt, QA Enginter

D. Pugh, Material Coordinator

Attended the Exit Meeting on August 12, 1988.

The inspector also held discussions with other licensee and contractor

perscnnel during the course of this inspection. +

2. Commercial Grade Procurement

To evaluate the licensee's commercial grade procurement program the

inspector specifically selected nine safety-related systems where known

commercial grade itetas are installed. These systems, the items supplied

and the respective vendors is presented in Table A. The associated >

Maintenance Report (MR) numbers are also referenced when identified by

the inspector. These items were pu, chased with the guidance provided in

implementing procedure NDP No. 300-3, "Evaluation of Commercial Grade

Items," and are designated as Quality Level Code C1. The quality level

classifications are astablished in NDP No. 300-1, "Procurement Quality

, level Classification System." The classifications for the safety-related

quality level codes are, A1, (full scope procurement) D1 (limited scope

procurement), C1 (commercial grade procurement). Code Al requires a

pre-award evaluation of the supplier's QA program. Code 01 requires

evidence that the supplier maintains an acceptable QA program (such as

being listed on the CASE Register) to produce valid quality verification

documentation prior to award of the contract. Code C1 items do not

require a formal QA program nor is the supplier required to be included

on the FGE Evaluated Contractors and Suppliers List. Also, according to

Table 1 of NDP No. 300-1, for C1 procurement, preaward supplier

evaluations and post-award supplier audits are "not allowed." This was

a procedural inadequacy to be corrected.

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TABLE A

System Items Supplied Vendor i

A. RC Head Vent A325 Bolts Liberty Equipment i

(MR No. 87-4988) 2" Sch 80 TP304 Pipe Liberty Equipment l

3/4" 1500 Blind Flange Liberty Equipment

TP 304 Plate Kipp Steel j

2" Sch 80 TP 304 Pipe Alaskan Copper & Brass

Flextallic Gaskets In-Mar Sales

B. RC-Pressurizer Spring Can Bergen-Patterson

Surge Line

C. RCP Seal Return Pipe Fittings M-C0 Northwest

Lines (Socket Welds)

(MR No. 87-1807) 1" Sch 160 TP304L Pipe Tioga Pipe Supply

1" Tee 6000# A182 F304 Liberty Equipment

3/4" 90* Elbow 316L Portland Valve

D. MS/AFW ASTM A36 Plate American Steel

(MR No. 87-2117) ASTM A500 Plate American Steel

E. MFW

(MR Nos. 87-4128, 14" Sch 60 Pipe Liberty Equipment

4129, 4130, 4169 14" Sch 60 Elbow Consolidated Power

and 4583) Welded Beam Attachment NPS Industries

F. SW 90-10 Cu-Ni Pipe Alaskan Copper & Brass

(IIR No. 87-4325)

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G. CCW A19387 Bolts Liberty Equipment

l H. EDG Pressure Switch Power Systems

(MR No. 86-4193)

I. Containment H y 2" Sch 40 TP304 Pipe Liberty Equipment

NDP No. 330-3 defines a commercial grade item as an item that is: ,

A. Not subject to design or specification requirements that are unique

to facilities or activities licensed or regulated by the NRC, and

l B. Used in applications other than facilities or activities licensed or

! regulated by the NRC, and

C. Ordered fiom a manufacturer /suppiter on the basis of specifications

set forth in the manufacturer's published product description (for

example, a catalog).

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The majority of the items listed in Table A are for replacement of items

originally installed to the requirements in Standard 831.7 entitled

"Nuclear Power Piping." For example, MR No. 87-4129 is for replacement

of Loop D Feedwater piping located inside containment. Documentation in

the MR package contained Engineering Instructions stating "This work is

safety-related. Installation of piping shall comply with Class 2 of ANSI

B31.7, 1969 Edition..." Since 831.7 is unique to the nuclear industry

the inspector questioned the licensee's justification for purchasing

these items as commercial grade, that is C1 as opposed to Al which

specifies QA requirements in the purchase order. The inspector

understood the licensee's response as follows: the rules and

requirements for replacements are provided in Article IWA-7000 of ASME

Section XI "Rules for Inservice Inspection of Nuclear Power Plant

! Components." IWA-7210 states that replacements shall meet the

l requirements of the Construction Code to which the original component or

part was constructed; which for this plant is 831.7. 831.7 requires ASTM

materials specifications for nuclear piping. Consequently, since ASTM

materials specifications are not unique to the nuclear industry, these

materials are purchased as quality level C1 items. Therefoce C1 items

may be purchased from a vendor's catalog with acceptance of the item

based solely on the Certificate of Conformance (C of C); with no need to

perform a vendor survey or specify Code QA requirements. C of Cs or

Materials Test Reports (MTRs) were provided for receipt inspection of the

safety-related items listed in Table A.

The licensee is committed to ANSI N45.2.13-1976 which states in Section

10.2.f that means shall be provided to verify the validity of supplier

certificates and the effectiveness of the certification program, such as

during the performance of audits of the supplier or independent

inspection or test of the item. Table B presents the status of PGE's

quality evaluation of the thirteen vendors that supplied C1 items for

insts11ation in safety-related systems identified in Table A, (except for

Cardinal Industrial Products). In seven instances no action had been

taken to verify the validity of the suppliers C of Cs. Audits were

performed in July 1984 on Liberty Equipment and Portland Valve. The

audits consisted only of an interview of the C of C signer. The audits

did not include a verification of the effectiveness of the certification

I system by examining such areas as material control, nonconformance

l control and inspection.

The licensee's procedure, NQAP No. 105 "Contractor and Supplier

Evaluations" requires that "at least 10 percent of the vendors that

provided Certificates of Conformance as required by QA Code C1 PCs,

during each year, shall be visited by the end of the following year."

Also, the ANSI N45.2.13 requirements-do not specifically state that these

surveys be performed prior to installation.

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TABLE B

ON Commercial Grade

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Vendor ECSL Survey

Bergen-Patterson. No He g

Liberty Equipment No Yes

Alaskan Copper & Brass No Yes

Kipp Steel No No

M-C0 Northwest No N

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Tioga Pipe Supply Yes Yes

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Portland Valve No Yes

American Steel No No

Consolidated Power Yes No

NPS Industries Yes 'Yes

Power Systems No No

In-Mar Sales No No

Cardinal Industrial Products 3 No No

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l Notes:

1. Verified validity of a supplier certificates by interviewing the C

of C signer.

2. Special audit of Tioga Pipe Supply and their subsupplier, Custom

Alloy conducted on June 6-8, 1988. These two companies together

with another subsupplier WFI Nuclear Products, produced the

(_ replacement material for the pressurizer surge line.

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3. Supplier of various size heavy hex nuts, with hardness

I specifications, for use in safety-related and non-safety-related

applications.,

4. Evaluated Contractors and Suppliers List.

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There are 80 vendors supplying C1 items; with 10% being audited each

year. The inspector recently reviewed the program for dedication of

commercial grade items used in safety-related applications which resulted

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in an open item (50-344/88-26-03). This open item has now been

reclassified as an unresolved item.

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3. Large Bore Pipe Support Design Verification Program

IE Bulletin (IEB) 79-02 required licensee verification of design and

construction adequacy of pipe support concrete expansion anchors. IE

Bulletin 79-14 required licensee verification that safety-related piping

systems had been constructed as designed. Specific detailed requirements

are contained in the bulletins. Inspection Report 50-344/86-05 verified

licensee compliance with IEB 79-02 requirements and closed IEB 79-02.,

Inspection Report 50-344/86-14 verified licensee compliance with IEB ,-

79-14 requirements and closed IEB 79-14.

A July, 1987 NRR sudit of Trojan pipe support design resulted in NRR

concerns regarding the adequacy of the Trojan IEB 79-02 and IEB 79-14

programs. The concerns were documented in a Mechanical Engineering

Branch trip report dated September 25, 1987. PGE has initiated a large

Bore Pipe Support Design Verification program due to piping / pipe support

anomalies encountered at Trojan and due to the NRR concerns. No

unresolved operability questions resulting from this program have been

reported to Region V to date; this is a continuing program.

No violations or deviations were identified.

4. Unresolved Items

An unresolved item is a matter about which more information is required

to ascertain whether it is an acceptable item, a deviation, or a

violation. An unresolved item is documented in paragraph 2.

5. Exit Interview

The inspector met with the licensee representatives denoted in paragraph

1 on August 12. With the exception of paragraph 3, the scope of the

inspection and the inspector's findings as noted in this report were

discussed.

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