ML20198R348
| ML20198R348 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/04/1997 |
| From: | Ford E NRC (Affiliation Not Assigned) |
| To: | Black S NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20198Q554 | List: |
| References | |
| NUDOCS 9711130246 | |
| Download: ML20198R348 (8) | |
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UNITED STATES j
j NUCLEAR RESULATORY COMMISSION j
wAsMiNatoN. D.C. 30eeHo01 September 4, 1997 MEMORANDVH T0:
Suzanne Black, Chief Quality Assurance and Maintenance Branch Division of Reactor Controls and Human Factors Nuclear Reactor Regulation FROM:
Edward J. Ford ' 'f d4' #,/ 8 -
Quality Assurance and Safety Assessment Ser. tion Quality Assurance and Maintenance Branch Division of Reactor Controls and Human Factors Nuclear Reactor Regulation
SUBJECT:
TRIP REPORT - NOVEMBER 21, 1996, ASSESSMENT OF THE GRAND GULF NUCLEAR STATION GRADED QUALITY ASSURANCE PROGRAM On Novemuer 21, 1996, members of the NRC staff met with representatives of Entergy at the Grand Gulf Nuclear Station (GGNS) to discuss the implementation methodologies employed for graded quality assurance in the procurement area.
The NRC staff reviewed the licensee's program for procurement of items used in safety-related, low-safety-significant aaplications and nonsafety-related, high-safety-significant applications.
T,1e )rocess used to categorize struc-tures, systems, and components (SSC), and t1e end results of the categorization process implementation, was not within the scope of the staff's review.
The staff held discos: ions with personnel from GGNS design engineering, procurement engineering, and regulatory affairs.
The staff concluded that GGNS has initiated a conservative effort to establish a graded QA process for procurement activities. This was evident in the limited scope of the graded arocurement activities and the application of graded QA controls for a num)er of purchase orders related to nonsafety-related, but safety significant items.
Based on a review of the GGNS QA program and implementing procedures for grading controls applied to the procurement process, and several low-safety-significant connercial grade item (CGI) dedication packages, the team ascertained that the GGNS procedural guidance for performing low-safety-significant procurement and CGI dedication activities lacked details as to how GGNS staff were to develop graded procurement controls.
The staff informed GGNS that it would be expected to further describe its graded quality assurance program methodology if it extended graded QA beyond what it is presently doing.
ERADED OA PROGRAM DESCRIPTION The staff reviewed recent revisions (Revisions 12 through 14) of the GGNS 97ii130246 971106 ADOCK0500g46 DR
S. Black September 4, 1997 GRADED OA PROGRAM DESCRIPTION The staff reviewed recent revisions (Revisions 12 through 14) of the GGNS 0)erational QA program to determine if the description and implementation of t,1e graded QA program conformed to licensee )ractices and regulatory require-ments.
It was anticipated that QA program c1anges would have been made as necessary to identify any QA program comitments which had been reduced.
The staff and GGNS personnel discussed the need for describing the explicit QA controls, for SSCs classified as low-safety-significant, in the GGNS QA program. The licensee informed the staff that, in its opinion, the current GGNS QA program adequately addresses the application of graded QA controls by stating that the requirements of Appandix B to 10 CFR Part 50 be applied in a manner commensurate with the safety significance of the $50.
The staff informed GGNS that although the QA program incorporated applicable text from Appendix B for applying QA controls commensurata with the safety significance of SSCs, that Section 50.34(b)(6)(11) requires that QA programs describe is the requirements of Appendix B will be satisfied.
The staff noted that the t
NRC letter to GGNS dated May 29, 1996, elaborates on the staff's position with respect to the necessity for the QA program to articulate how previous commit-ments will be adjusted for purposes of graded QA.
Therefore, the staff's position is that if QA commitments are reduced as part of the GGNS application of graded QA, that the GGNS QA program would need to be revised as necessary.
Graded 0A Proaram and Imolementino Procedures In addition to reviewing the GGNS QA Program description the staff reviewed the following procedures to e/aluate the procedural controls for implementing graded procurement and commercial grade item (CGI) dedication activities, GGNS-General Engineering Standard (GES)-04, " General Engineering a.
Standard for Determining Safety Classification of Systems, Components and Parts," Revision 1, dated May 6, 1996.
b.
GGNS-GES-05, " Engineering Standard'for Technical, Quality and Documentation for Procurement," Revision 2, dated May 6, 1996.
c.
GGNS-GES-14, " Engineering Standard for Commercial Grade Item Evaluations for Replacement Items, Safety Ralated," Revision 0, dated May 6, 1996.
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GGNS Nuclear Plant Engineering Procedure Number 344, " Responses to Engineering Requests," with Change Notices 215 and 213, dated August 26, 1996, and June 3, 1996, respectively, e.
GGNS Administrative /rocedure Number 01-S-09-1, " Procurement of Materials, Safety Related," Revision 36, dated August 7, 1996.
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GGNS Administrative Procedure 01-S-03-3, " Material No1conformance Reports (MNCRs)", Revision 31, dated September 30, 1996.
g.
GGNS Administrative Procedure 01-S-03-10, "GGNS Condition Report (CR)
Safety Related," Revision 0.
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4 S. Black September 4, 1997 h.
Frocurement Evaluation Request Response (PERR) 96/0095, Revision 1.
The GGNS application of graded QA for procurement involves a change of sitt practices in that safety-related, low-safety-significant equipment can be-procured from commercial sources and dedicated for use rather than procuring from Appendix 8 suppliers. The staff considers that this approach conforms with regulatory requirements and existing GGNS QAP provisions provided that critical characteristics are appropriately identified and verified in accordance with 10 CFR Part 21.
Requests for the procurement of items-are processed in accordance with Procedure No. 01-5-09-1.
Section 5.22 of GGNS Procedure 01-5-0g-1 had been amended to state that graded QA is a process where the GGNS Operational QA program is applied in a manner commensurate with an item's importance to safety. Significant items may receive more quality assurance oversight than items that are low-safety-significant.
Section 6.1.1.h(3) specifies that the
- Materials Technical reviewer ascertain from Aspendix C of the Q-list whether the items have been affected by Graded QA. Tie applicable database identifies the classification of the item as safety-related, nonsafety-related, high-safety-significant, or low-safety-significant, or a combination thereof.
Engineering Requests (ERs significant items and non)afety-related, safety significant items so thatshall be initiat s
appropriate procurement controls can be identified, it is a function of Design Engineering, Procurement Engineering nction to review requests for the procurement of items, including performing a rev,iew of the item's safety-significance classification and safety classification in accordance with procedures GGNS-GES-04 and GGNS-GES-05.
GGNS Procurement Engineering personnel informed the staff that because the item's safety significance categorization in the data base is often predicated uponithe safety-significknce classification of the system or parent component, it is necessary for engineering staff to evaluate the specific function of the item procured..GGNS personnel further explained that procedure GGNS-GES-05 con-tains provisions for the Procurement Engineering Section to evaluate each item to be purchased on a case-by-case basis and that following the documented engineering evaluation, there may be a need to update the data base safety classification of the item being procured.
The staff noted that Section 7.0 of Procedure GGNS-GET. 05, described the relationship of quality controls based on safety significance determination.
The-application of reduced quality controls.is permitted in situations where
- quipment has=been defined as nonsafety-significant in Appendix C of the Q-list, or when the component-is listed in the Component Database (CDB) as NSS.
Once the correct safety significance categorization and safety classification has been determined, an evaluation is made to determine'if the item should be purchased as a CGI and dedicated as a basic component or purchased from a supplier having an approved QA program.
Procedure GGNS-GES-14 is used for controlling the_ dedication of CGis -to be used in both high-safety-significant and low-safety-significant, safety-related applications.
Procurement Engineering: personnel informed the team that the dedication of high-safety-significant and low-safety-significant CGIs are being performed in the same
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i S. Black September 4,1997 manner and that GGNS had not procedurally established graded QA procurement I
controlsforitemsclassifiedaslow-safety-significan",irectstheengin safety-related. The i
staff noted that GGNS procedure GGNS-GES-14 currently d staff to refer to the EPRI Electric Power Research Institute) Commercial Grade Item Joint Utility Tas(k Group results for use in identifying critical characteristics and associated acceptance criteria.
The staff questioned what changes in QA practices would be part of the graded QA program implementation.
GGNS staff stated that Amendment 14 of the QA program allowed the use of personnel to perform inspections which did not fully meet the experience requirements of ANS!_N45.2.6, and that its QA program description noted an exception to ANSI N45.2.6 in this area.
The NRC staff determined that an exception to ANSI N45.2.6 does not appear to have-been processed specifically for graded QA because it is applicable for all safety-related inspections (both high-and low-safety-significant).
Members of GGNS Design Engineering informed the staff that although its QA program provides for graded QA in the procurement area, several of its implementing procedures would have to be revised to implement this activity.
The team was further informed that the Design Engineering and Procurement Engineering grou)s would be reviewing and evaluating various graded QA verification met 1ods for dedicating low-safety-significant,-safety-related SSCs.
The staff discussed the examples of applying methods discussed in the NRR Draft Evaluation Guide, graded QA verification
" Development of Graded Quality Assurance Programs," Draft Revision 5, dated January 1996.
Addi-tionally, GGNS and the staff discussed examples of graded QA controls that would be appropriate for incorporation into the implementing procedures.
For example, procedures could be revised to provide the basis for and address the use of, reduced sampling when verifying critical characteristics for the dedication of low-safety-significant SSCs.
t Procedure GGNS-01-S-03-3, for processing material Condition Reports significant equipment, there(c) of the procedure states that for lo was reviewed.
Section 6.2.l safety-is a need to consider if the nonconformance affects or is applicable to safety significant SSCs.
The additional actions needed to address the problem for the safety significant SSCs is determined.
Additionally, if the nonconformance is found to affect safety significant SSCs, then the significance determination my be affected.
Similar provisions are discussed in Procedure GGNS-01-S-03-10.
If repeat problems are found, then the recurrences are evaluated for acceptability and adequacy of past corrective actions. The CR response shall document the evaluation of the problem recurrence..GGNS staff discussed the as on low-safety-significant items every-two years.pect of performing a QA trend All work orders will be routed through performance and system engineering to identify generic implications.
The staff reviewed _PERR 96/0095, Revision 1,'that describes technical guidelines for hanoling procurement of nonsafety-related equipment that has been categorized as safety significant. The guideline specifies that in accordance with GGNS-GES-05, Section 4, an engineering evaluation is performed to verify the safety significance of-the component, and to determine the level of quality control for the component, in the area of corrective actions, GGNS
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$. Black September 4, 1997 procedures for root cause analysis (01-5-17-38) and nonconformance procedures 3
(01-5-03-3) were characterized as requiring review of common mode failures for nonsafety-related components. Safety sign <ficance determinations are to be documented on Condition Reports and a reevaluation of the significance determination is also to be performed.
t PERR 96-0095 further specifies that for procurement of nonsafety-related, i
safety significant components, where there is no adverse performance history (i.e. a nonconformance document does not exist describing an adverse condition that could.be corrected by additional QA controls that existing stock purchased prior to January 1, 1996, can be used as), directed by the licensee's i
expert panel.
Upon reorder of stock, appropriate GGNS staff shall s>ecify-the technical, quality, and receipt inspection requirements to ensure lico-for-like replacement;.
Necessary receipt inspections shall be performed by certified receipt inspectors.
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Graded 0A Dedication Packaaes Reviewed The staff reviewed several procurement and CGI dedication packages to evaluate the GGNS implementation of the procedural controls for graded procurement and CGI dedication activities to ensure that the CGI, once dedicated, would be capable of performing their intended safety function. The staff's review included safety-related CGI dedication packages for items used in low-safety-significant applications as well as nonsafety-related >rocurement packages for items used in high-safety-significant applications.
Tae following examples are typical of the items that GGNS had purchased using graded QA controls.
Safety-Related, low-Safety-Significant Packages:
PERR No. 96/0032, Revision 0, dated February 20, 1996, described the dedication plan for the procurement and dedication of five carbon resistors used in various printed circuit cards of 16 low-safety-significant parent panels. The critical characteristics verified by visual examination included markings and identification (e.g., resis. tor color-codes), part number, and dimensions. The critical characteristics verified by test included the measurement of the resista~e.
GGNS Procurement Engineering personnel informed the stFT that because of the small number of resistors purchased, all resistors were subjected to visual examination and testing.
The staff questioned whether reduced sampling plan provisions were in place for dedicating CG!s to be used-in low-safety-significant applications.
GGNS staff informed the team that they use sampling during the dedication process on a selective, case-by-case basis. They presently have no provisions in their CGI dedication procedures to use reduced sampling plans for-the dedication of CGIs to be used in low-safety-significant applications.
The staff was informed that the initial five resistors received from the commercial supplier were all rejected because of incorrect color coding and resistance.
Procurement engineers further explained that the rejection of the five resistors provided an example of why sampling is used on a selective basis and not for small quantities of dedicated items.
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S. Black September 4, 1997 Engineering Request 96/0710-00, Revision 0, dated October 8, 1996, described the dedication plan for the procurement and dedication of a 3-pole, 30 A, 600V, contactor used in safety-related electrical components.
Procurement engineers informed the team that after contacting the supplier, they detar-mined that like-for-like replacement contactors were still available and decided that it would be advantageous to procure these contactors as safety-related rather than to purchase them as CGis and dedicate them as basic components.
Non$afety-Related and High-Risk-Significant:
Plant staff identified that approximately 70 - 80 instances had occurred where i
the application of QA controls was enhanced for nonsafety-related equipment based upon the recognition of their relatively greater safety significance.
---Procurement Evaluation Request (ER) No. 96/0048-00-02, dated November 7 -1996, described the procurement process for-a nonsafety-related 18-inch valve used in a high-safety-significant application. The valve serves as the plant service water pump discharge isolation valve.
In recognition of the valve's importance, CGI acceptance criteria and dedication methods were identified. This included specifying: 1) a 100%
visual inspection of the part number on both the hardware and associated vendor documentation; 2) 100% dimensional checks between the valve and respective vendor drawing; and 3) a 100% visual inspection of the valve body epoxy coating. The staff reviewed the associated Material Receiving (MRR /
Inspection Report (MIR) which documented the following receipt inspections) for the valve:
- 1) Item identification and review of Certificats of Conformance and packing slip, 2) dimensions, and 3) valve body coating material and extent of valve coating.
The staff additionc11y reviewed PERR 96/0022 Revision 0, for the procurement of a throttle cable for the nonsafety-related (but safety significant) diesel-driven fire pump.
The critical verification aspect was delineated as the nominal cable length and the Material Receiving (MRR) / Inspection Report (MIR) documented the associated verification.
The Procurement Evaluation Request that was initit.'.ed for the cable procurement under the graded QA approach was reviewed.
Procurement Engineering had reviewed the application of the cable and had determined the appropriate verification elements for it.
In conjunction with reviewing the procurement and dedication packages, the-team reviewed applicable procedures controlling these activities as well as the GGNS Operational Quality Assurance Manual - Revision 14. dated-December 18, 1995. The team concluded that the procurement activities reviewed were processed as required by applicable procedures and the Operational Quality Assurance Manual and that these procedures and manual describe an acceptable procurement and CGI dedication process.
However, as discussed earlier in this trip report, the staff notes that neither the Operational Quality Assurance Manual nor the implementing procedures reviewed described the methodology. for grading the quality controls for the procurement of safety-related items used in low-risk-significant applications.
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S. Black 7-September 4, 1997 Gradina of Quality and Technical Reauirements The staff and members of Procurement and Design Engineering discussed the intent of a handout that had been presented by the licensee during several meetings with the NRC staff.
Relative to the application of 10 CFR Part 21, the GGNS handout stated: "for identical components in safety significant vs.
low safety significant applications: The number of critical characteristics will vary (more critical characteristics for safety significant applica-tion)... The level of control exerted over a single characteristic will vary (more stringent controls for safety significant application)." The staff began the discussion by referencing correspondence to NRC 14censees such as the NRR Draft Evaluation Guide, ' Development of Graded Quality Assurance Programs," Draft Revision 5, dated January 1996, that identifies the staff's position on the grading of critical characteristics as part of the graded QA process.
The team stressed that it was the staff's position that licensees may establish less stringent quality assurance requirements for the procure-ment of low-safety-significant items than for high-safety-significant items, it was further discussed r in implementing these less stringent require-ments, licensees need to.... sider the various CGI dedication issues and 10 CFR Part 21 requirements as well as possible 10 CFR Part 50, Appendix B require-ments, as implemented through applicable regulatory guides.
Within this area, the team stated that the technical requirements for CGI dedication in accord-ante with 10 CFR Part 21 (e.g., critical characteristics of an item for an application) are ag.t subject to grading.
However, for items of low-safety-significance, the verification of critical characteristics may be graded (e.g., use of reduced sampling plans, or alternate testing and inspection techniques).
The GGNS Design and Procurement Engineering representatives agreed with the team that grading of technical requirements was not part of the graded QA process and that changes to technical requirements would be processed as design changes and in accordance with the 50.59 process.
The GGNS represen-tatives also agreed that the referenced handout could be misinterareted and could have been worded differently to clearly indicate that for tae same item used in different applications, the critical characteristics may vary.
GGNS presented the following example:
A valve is purchased commercial grade ano dedicated for use in a high-safety-significant application that requires that the valve open and close to perform its intended safety functions.
The critical characteristics varified include pressure boundary integrity verifications as well as those ai,st,ciated with the valve opening and closing.
The umt valve is used in a low-safety-significant application with an end use that requires that it only open to perform its safety function, therefore there is no need to verify the critical character-istics associated with the valve closing.
Attachments. As stated
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Grand Gulf Personnel Contacted C. E. Brooks Sr.
Licensing Specialist - NSLRA it ikitner Director, NS&RA K. ri'rihey Technical Advisor C. Abott Supervisor Quality S: Saurdeis Manager ME/IE 0..Benway Engineer G. :mith Sr. Staff Engineer / Safety Anal sis M. Miri Supervisor Procurement D. Wiles Supervisor Procurement Engineering-L. De9?htery Technical Cocrdinator r
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