ML20154N895
| 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: |
| 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
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REGION V
Report No:
50-344/88-39
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Docket No:
50-344
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License No:
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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
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5. ~ .
chards, Chi
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iKte41gned
eering Sectio
Sumary:
Inspection During the Period of August 8-12, 1988
(Report 50-344/88-39)
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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
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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.
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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
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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
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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
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A.
RC Head Vent
A325 Bolts
Liberty Equipment
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(MR No. 87-4988)
2" Sch 80 TP304 Pipe
Liberty Equipment
3/4" 1500 Blind Flange
Liberty Equipment
TP 304 Plate
Kipp Steel
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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.
(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.
90-10 Cu-Ni Pipe
Alaskan Copper & Brass
(IIR No. 87-4325)
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G.
A19387 Bolts
Liberty Equipment
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H.
Pressure Switch
Power Systems
(MR No. 86-4193)
I.
Containment H
2" Sch 40 TP304 Pipe
Liberty Equipment
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NDP No. 330-3 defines a commercial grade item as an item that is:
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A.
Not subject to design or specification requirements that are unique
to facilities or activities licensed or regulated by the NRC, and
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B.
Used in applications other than facilities or activities licensed or
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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
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example, a catalog).
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The majority of the items listed in Table A are for replacement of items
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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
B31.7Property "ANSI code" (as page type) with input value "ANSI</br></br>B31.7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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
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Components." IWA-7210 states that replacements shall meet the
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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
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system by examining such areas as material control, nonconformance
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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
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Vendor
ECSL
Survey
Bergen-Patterson.
No
He
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Liberty Equipment
No
Yes
Alaskan Copper & Brass
No
Yes
Kipp Steel
No
No
M-C0 Northwest
No
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Tioga Pipe Supply
Yes
Yes 3
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
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Cardinal Industrial Products
No
No
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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
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replacement material for the pressurizer surge line.
3.
Supplier of various size heavy hex nuts, with hardness
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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.
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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