ML20155B880
| ML20155B880 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/10/1988 |
| From: | Randazza J Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| MN-88-80, NUDOCS 8810070113 | |
| Download: ML20155B880 (3) | |
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MaineYankee phqsteemmy pon una s %cs t,9 LDISON DmVE. AUGUSTA. MAINE 04U0. U07) 622 4868 August 10, 1988 HN-88-80 Region !
United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Attention: Mr. H1111am T. Russell, Regional Administrator
References:
(a)
License No. OPR-36 (Docket No. 50-309)
(b) HYAPCo Procurement Audit Letter to USNRC dated July 12, 1988 (MN-88-72)
Subject:
NRC Procurement Inspection (88-200)
Gentlemen:
Reference (b), summarized Maine Yankee's planned actions regarding procurement practices as a result of concerns expressed during an NRC procurement / vendor interface inspection at Maine Yankee.
At the exit meeting of this inspection, held on July 22, 1988 Maine Yankee described an additional action that we plan to take. Attachment A summarizes the actions that will be taken to improve our procurement practices and to verify the adequacy of our past practices. As previously indicated, we will provide you with a status report of our actions by the end of October, 1988.
We have performed an evaluation to help us assess the possible safety significance of our past procurement practices. Our interim review of the 55 purchase orders, identified by the NRC as exarples of questionable procurement practices, did not reveal anything that was considered to be a possible safety problem. He verified that replacement parts which were procured as comercial grade items met either the original purchase or catalog specifications, where they existed, or were a:onsidered suitable for their intended application.
Maine Yankee reported approximately 200 equipment failures in safety class systems which occurred during the past five years to INPO's Nuclear Plant Reliability Data System (NPRDS). Fifty of the 200 equipment failures were associated with components classified as Procurement Level 2 (i.e., commercial grade item). Of these, there were e.iy four possible failures that could be attributable to changes or daficiencies in either the design or manufacturing process. Two were failures of originally purchased equipment and the other two were bearing failures that occurred because of improper machining and specifications.
This review provides us assurance that replacement components procured as comercial grade items have not adversely affected safe plant operation and are suitable for application in safety class systems.
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EoISON oRIVE, AUGUSTA MAINE 04330. CC7) 622 4248 August 10, 1988 HN-88-80 l
Region I United States Nuclear Regulatory Comission 475 Allendale Road King of Prussia, Pennsylvania 19406 Attention: Mr. Hilliam T. Russell, Regional Administrator 3
References:
(a) License No. OPR-36 (Docket No. 50-309)
(b) HYAPCo Procurement Audit Letter to USNRC dated l
July 12, 1988 (HN-88-72)
Subject:
NRC Procurement Inspection (88-200)
Gentlemen:
Reference (b), sumarized Maine Yankee's planned actions regarding procurement practices as a result of concerns expressed during an NRC procurement / vendor interface inspection at Maine Yankee. At the exit meeting of this inspectioa, held on July 22, 1988, Maine Yankee described an additional action that we plan to take. Attachment A summarizes the actions
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that will be taken to improve our procurement practices and to verify the j
adequacy of our past practices. As previously indicated, we will provide you 1
with a status report of our actions by the end of October, 1988.
He have performed an evaluation to help us assess the possible safety
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purchase orders, identified by the NRC as examples of questionable procurement significance of our past procurement practices. Our interim review of the 55 l
practices, did not reveal anything that was considered to be a possible safety problem. He verified that replacement parts which were procured as comercial grade items met either the original purchase or catalog specifications, where they existed, or were considered suitable for their intended application.
1 Maine Yankee repvrted approximately 200 equipaent failures in safety class systems which occurred during the east five years to INPO's Nuclear Plant 3
Reliability Data System (NPROS), sifty of the 200 equipment failures were associated with components classified as Procuremer,t level 2 (i.e., comercial grade item). Of these, there were only four possible failures that could be attributable to changes or deficiencies in either the design or manufacturing process.
Two were failures of originally purchased equipment and the other specifications.g failures that occurred because of improper machining and two were bearin This review provides us assurance that replacement components procured as comercial grade items have not adversely affected safe plant operation and are suitable for application in safety class systems.
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t MaineYankee United States Nuclear Regulatory Commission Page Two Attention: Mr. Hilliam T. Russell HN-88-80 The seismic ruggedness of the Maine Yankee plant systems and components has been demonstrated, through the NRC-sponsored seismic design margins program (SDHP), to be well beyond its original design basis.
Furthermore, the seismic adequacy of IE replacement components has, excluding the generic itsue of seismically induced inadvertent change-of-state in relays, been shown to be acceptable for a range of components using the seismic experience data base prepared for the Seismic Qualification Utility Group (SQUG).
The Maine Yankee plant has operated safely and reliably for sixteen years.
The assurance of quality has been a fundamental criterion that has been applied to every aspect of the facility including, but not limited to, its design, construction, operation, maintenance, testing and repair.
Based on my assessment of the evaluation we performed, and my own experience with the Company, I have concluded that the quality assurance practices associated with our procurement program provide reasonable assurance that the overall quality of plant safety systems and structures have been maintained.
Our evaluation also indicates that our past procurement practices were in compliance with NRC requirements and were typical of the practices of other plants of similar vintage.
The concerns raised by the inspection team in this area appear to be based on new NRC requirements.
He will complete the remaining actions in Attachment A to provide further assurance that quality assurance aspects of our procurement practices have maintained the overall level of quality of the plant.
Interim measures are already in place that reflect the EPRI guidance for procuring and accepting commercial grade items. He will retain a consultant to assist us in reexamining the adequacy of our past procurement practices on a sample of the past five years' procurements. He plan to have all actions listed in Attachment A completed and appropriate resolutions implemented by February 28, 1989. Mr. John H. Garrity, Vice President of Quality Programs and Engineering, is personally overseeing the completion of the corrective actions.
If you have any questions, please do not hesitate to contact Mr.
Garrity at (207) 622-4868 or me at (207) 623-3521.
Very truly yours, MAINE YANKEE WM!
w John B. Randarza President SDE/bjp Attachment A c:
Mr. Richard H. Hessman Mr. Patrick H. Sears Mr. Lowell Tripp NRC-Region I Hr. Cornelius F. Holden 0358L-SDE
MaineYankee ATTACHMENT A (MN-88-80)
Maine Yankee Commitments in Response to NRC Inspection 88-200 (Supersedes MN-88-72) l 1.
He will reassess our criteria for classifying purchases as 1
procurement level 1.
l 2.
He will change our procedures to require that 10 CFR 21 be identified i
i as being applicable on all procurement level 1 purchases.
3.
We will modify our purchasing procedures to take into account the l
guidance provided in the EPRI document, "Guideline for Uti11 ration of t
l Commercial Grade Items in Nuclear Safety Related Applications."
l 4.
He will review purchases made during the last five years to identify procurement level 2 purchases.
These purchases will be evaluated on i
a sample basis to ensure that replacement components are equal to or better than the original equipment. He will retain a consultant with expertise in this area to assist us in this effort.
5.
He will perform a review of equipment failures reported to the NPRDS during the last five years to identify any associated with a defective replacement part purchased as procurement level 2.
e 6.
He will evaluate the specific procurement concerns associated with
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the 55 Purchase Orders identified by the inspection team during the i
i June 10, 1988 meeting, i
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