ML20196C852

Rev 2 to Procurement Engineering Assessment Plan

ML20196C852
Person / Time
Site:	Rancho Seco
Issue date:	01/27/1988
From:	SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20196C568	List: ML20196C565 ML20196C852
References
PROC-880127, NUDOCS 8802160258
Download: ML20196C852 (18)

Text

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n PROCURENENT ENGINEERING ASSESSMENT PLAN OUTLINE I. BACKGROUND / INTRODUCTION II. TASK ACTION PLAN

1. PURPOSE

2. PROJECT SCOPE

3. EVALUATION TECHNIQUES

4. PROJECT ORGANIZATION 1

III. SCHEDULE IV. RESOURCES V. ATTACHMENT

1.

SUMMARY

OF DISTRICT COMMITMENTS 8G0216025G 880203 PDR ADOCK 05000312 R PDR_

Rev. 2, 1/27/88

Revision History PROCUREMENT ENGINEERING ASSESSMENT PLAN ,

REVISION DATE DESCRIPTION OF CHANGES Original 1/21/88 (Version informally discussed with the NRC.)

Rev. I 1/21/88 Minor editorial changes (spelling / sentence structure / references). Added page numbers.

II.2.2 D Updated to show current practices.

II.2.2 F Revised surveillance performance ,

from "each action" to "specified actions".

Figure 2-2 Revised to reflect actual sample plan.

Rev. 2 1/27/88 Revised I to add "Background" section.

Revised II.2.2 D to reflect actual conditions and revised commitment on future actions.

Minor editorial changes II.2.2 F.

Revised Functional Organizational Chart to ,

reflect current personnel and projects.

III.2.5 indicated that only specified actions would be subject of surveillances.

Deleted Attachment 1 (3 pages) since it was out-dated. The attachment was a copy of material previously furnished to the NRC during the January 1988 inspection.

Clarified "Summary of District's Commitments" to incorporate subsequent discussions and evaluations.

Rev. 2, 1/27/88 i

j PROCURDfBNT ENGINEERING ASSESSNENT PLAN I

1

1. BACKGROUND In its continuing effort to review & upgrade Rancho Seco programs and Practices, the District formed a Material Control Assessment Team composed of representatives form Materials Management, Maintenance, Nuclear Engineering, Nuclear Licensing..and Quality Assurance. One of the principal areas that this team has been focusing on is the past practice of procuring items on a "Like-for-Like" basis. The following background discussion on Commercial Dedication characterizes the overall concern and introduces the actions currently in process.

Based on a number of programs and activities completed in 1987, Rancho Seco management has adequate confidence that items procured from unapproved suppliers which are installed in Class-1 systems will perform satisfactorily in service. In addition, based on the changes made in materials management and procurement practices along with concomitant revision to engineering proce-dures, Rancho Seco management is confident that controls relative to commercial grade item procurement, storage, and dedication meet the requirements of 10CFR21 and 10CFR50, Appendix B.

Many items procured as commercial grade which were installed in Class-1 systems were also entered into warehouse stock. A program of re-verification of warehouse items in this category, underway and scheduled for completion by 9/30/88, is verifying that these items will meet the current Rancho Seco controls applied to commercial grade items. Any items found unacceptable by this program will cause an investigation to determine if a similar part is installed in the plant. Before items will be issued from the warehouse for use in Class-1 systems, they will have completed the re-verification process, and will have been dedicated for the intended application.

Although management has the adequate confidence required by 10CFR50, Appendix B that structures, systems and components will perform satisfactorily in service, additional confidence is desired since it is acknowledged that commercial grade dedication

- practices in the past were not as strong as current practices.

Although numerous independent reviews and tests have evaluated structures, systems or components, these reviews did not focus specifically on commercial grade item dedication (CGID).

Audits by the NRC. INPO, utility groups, and Rancho Seco QA on controls previously in place, while demonstrating overall adequacy, may also lack specific focus on verification of the dedication of commercial grade items installed in Class-1 systems.

Rev. 2, 1/27/R8 1

However the primary reason why additional confidence is desired stems for the commitment of Rancho Seco and the SMUD to restart and operate the plant in a manner which goes beyond meeting the minimum requirements. It is the commitment to excellence which is the most compelling reason for initiating this Rancho Seco Action Plan for Commercial Grade Items Installed in Class-1 Systems.

An example of that commitment to excellence is the direction of the CEO to implement this Plan.

I.1 PLAN INTRODUCTION During the period of January 4-14, 1988, the NRC conducted an inspection of Procurement and Materials Control Practices at Rancho Seco. This inspection concentrated on past as well as current practices. During internal evaluations made in preparation for the NRC inspection, SMUD identified certain weaknesses in past Material Control practices. In response, a draft assessment plan was developed and presented to the NRC at the inspection entrance meeting on January 4, 1988. The assessment plan was reviewed by the NRC Inspections Team and compared to their findings.

This Procurement Engineering Assessment Plan expands on the assessment plan discussed previously, taking into consideration j the comments and findings of the NRC Inspection Team. The actions deset ibed herein provide a comprehensive plan to address concerns and observations expressed during the inspection. The i primary objectives of this action plan are:

l l o Provide a high degree of confidence that the as-installed configuration of Rancho Seco is consistent with safety

operability goals for restart; I

l o Address concerns identified by the NRC Procurement and j

Materials Control Inspection.

! This action plan addresses both specific and generic actions, on

both a restart and long-range action basis. The primary restart concerns relate to four key issues:

o Commercial Grade Item Dedication (CGID),

o Seismic qualification (SEQ) of relays in the Reactor Protection System and Safety Features Actuation System (SFAS),

o Piece-parts environmental qualification (EQ),

o Enhancement of existing procedures / processes.

Each of these issues is addressed, along with necessary support tasks, in Section II. The schedule and resource requirements for project completion are addressed in Sections III and IV respectively.

Rev. 2, 1/27/88 2

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II. TASK ACTION PLAN r 11.1 PURPOSE I

Define the assessment program initiated by SMUD to evaluate current and past Material Control practice at Rancho Seco. This task Action Plan was modified following the NRC Procurement Inspection performed during the period of January 4-14, 1988.

This assessment will focus on the purchase of Commercial Grade Items used in safety-related applications. The evaluation results must provide Management with confidence that installed equipment will provide for safe operation or additional actions will be initiated.

II.2 PROJECT SCOPE Il.2.1 INITIAL PROGRAM Prior to the NRC Inspection, SMUD prepared a "Rancho Seco Assessment of Commercial Grade Items Installed in Class I Systems." This approach was initially based on:

A) The results of technical programs completed as described in the Engineering report "Engineering Evaluation of the Suitability of Installed Equipment."

Other programs related to Procurement and Material Control were included in a SMUD report "Assessment of Materials Management Practices at Rancho Seco" (previously provided to the NRC). A comprehensive Stock Material Reverification effort is underway and is targeted for completion by September 30, 1988.

B) An evaluation to consider the adequacy of installed Commercial Grade Items. The evaluation included two phases:

o A review of plant problem reports to determine if Commercial Grade Item failures caused or contributed to past operational problems and, o A review of Class I Serialized Work Requests involving the installation of Commercial Grade Items in Class I systems. A Commercial Grade Item Dedication Evaluation was to be accomplished on a sampling basis using today's methodology.

Rev. 2, 1/27/88 3

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