ML20235G118
| ML20235G118 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/17/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8902230124 | |
| Download: ML20235G118 (74) | |
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Portland General ElectricCcntpany David W. Cockfield Vice President, Nuclear February 17, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 l
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sirs:
Justification for Continued Operation (JCO) for Commercial-Crade Procurement Issues On November 29, 1988, a JC0 was prepared which addressed issues associ-ated with apparent deficiencies in the procurement of commercial-grade equipment used in safety-related applications. As committed to you during a February 8, 1989 conference call, Revision 1 to this JC0 has been prepared and is enclosed for your review. This JCO describes the status of the program at this t.ime. Review of commercial-grade issues is an ongoing effort. Also, enclosed are responses to questions raised during this conference call.
Sincerely, k
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[Q@ c: Mr. Joht B. Martia cao Regional Administrator, Region V
$8 U.S. Nuclear Regulatory Commission CO O eM hr. William T. Dixon M State of Oregon Department of Energy c4
$Cc Mr. R. C. Barr
{f@g NRC Resident Inspector d Trojan H :c tw.?r Plant 121i W % Pawc Oregon 97204
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Trojtn Nuclear Plcnt Docum nt Control D3sk Docket 50-344 Fs eruary 17, 1989 License NPF-1 Attachment A Page 1 of 2 RESPONSES TO NUCLEAR REGULATORY COHMISSION (NRC)
<EQUESTS FOR ADDITIONAL INFORMATION QUESTION NO. 1 Further explain how Portland General Electric (PGE) verified that commercial-grade items were not used in anvircnmentally qualified (EQ) applications.
Response: l Section II [Page 2 of Justification for Continued Operation (JCO)]
provides the results of the Installed Items Review which shows that commercial-grade items were not used in harsh-environment EQ applications.
QUESTION NO. 2 Expand the discussion of how PGE justified the use of commercial-grade items in seismic applications.
Response
1 Section II (Page 2 of JCO) provides a summary statement regarding seismic qualification and references the results of the Installed Items Review (Attachment 2 of Table 12).
QUESTION NO. 3 For the feedwater piping installation in 1987/88, was impact testing required and was it performed?
Response
Impact testing is addressed on JCO, Page 64.
QUESTION NO. 4 Has PCE dealt with the issue of homogeneity in the different heats of material for mechanical components?
Responset The issue of homogeneity for mechanical / structural materials within the same heats is addressed in JCO, Page 64.
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h yr Trojcn Noclasr Plantf -Docum:nt Control D2sk, Docket 50-344- February 17, 1989 License NPF-1 Attachment A Page 2 of 2 OURSTION NO. 5 Include in the JCO what:PGE has done to address weld-rod'and 1stener acceptability.
Response
Mechanical Technical Evaluation (MTE) M-10.was added to the JCO (Page 71) to address weld-rod acceptability. Fastener acceptability is addressed in MTE M-2 (JCO Page 62) l- -QUESTION NO. 6 Confirm to the NRC that material bought for use in EQ applications has only been bought'from qualified vendors.
Response
This JCO evaluated the uses of commercial-grade material issued from the warehouse and installed in safety-related, including EQ, applica-tions. Additional discussion of programmatic controls is on Page 5 of the JCO.
QUESTION NO. 7 Describe to tbs NRC PGE's plan to proceed from this point and verify v the acceptability of all other commercial-grade material uses in safety-related applications.
Response
The action plan referenced in Section III (JCO, Page 6) provides the actions necessary to verify the acceptability of commercial-grade items used in safety-related applications. Part of this action plan requires a review and evaluation of all quality-related Maintenance
' Requests issued between September 1, 1985 and December 31, 1938. This
.will provide further assurance that all installed commercial-grade items in safety-related applications have boon evaluated for acceptability.
In addition, the procurement process has been revised to evaluate commercial-grede items using current requirements, including Electric Power Research Institute (EPRI) Report NP-5652. A group has been dedicated to this task.
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' Podland Gen:ral Elodric Nuclear Division L
i' MEMORANDUM.
TO: ' Distribution 'ANR-0236-89M JC0 88-15 FROM: A. N. Roller Revision 1 DATE: - February 17, 1989
SUBJECT:
Justification for Continued Operation (JCO)
Revision 1 addresses specific questions raised by NRC staff in a February.7, 1989 telephone conversation.
1, Existing Conditions Dur.ing inspections (Attachment A. Reference 1 and 2) performed by the Nuclear Regulatory Commission (NRC) Vendor Program Branch in 1985, deficiencies were identified in Trojan Nuclear Plant' activities relating to the procurement of safety-related .
components. This.resulted in the issuance of a Severity Level IV
' violation.
Recent~ inspections (Attachment A, Reference 3 and 4) performed by NRC Region V have again identified deficiencies with safety-related' procurement. Specifically, the deficiencies are as follows:
- Inadequate quality surveys to establish the effectiveness of vendors to certify items supplied commercial grade.
- Lack of technical attention to adequately specify and verify the suitability of items purchased commercial grade.
- Inadequate programmatic controls for commercial grade items procured and dedicated for use in safety-related systems.
Although Portland General Electric (PGE) has instituted new programs and practices (eg, in the selection, receiving inspection and testing of items), inadequacies'in satisfying regulatory requirements as it pertains to these two. deficiencies remained unresolved. In October of 1988, PGE issued a Nonconforming Activities Report (UCAR) P88-212 (Attachment A. Reference 5) to address these deficiencies as nonconforming activities as it pertains to 10 CFR 50, Appendix B, criterion IV and Criterion VII.
II. Justification for Operation with Existing Conditions continued operation is justified based on conclusive results of a review conducted on the following:
- Data from existing performance monitoring programs (for equipment failure trends attributed to items purchased commercial grade and used in safety-related applications). This review is detailed in Section II.B below.
JC0 88-15. Rev. 1 Page 1 of 71 Trojan Excellence-Our Way of Doing Business
Ponland G:neral El:ctric Nucl:ar Division Distribution February 17, 1989 Page 2 Procedures and Practices. See Section II.C below.
All warehouse commercial grade materials issued from January 1986 through November 1988, comprising 20,000 items, were reviewed in detail to ensure functional adequacy of installed items. Using this database, no commercial grade items were found to be installed in applications which affect harsh-environment.EQ. Material tests of over 200 mechanical / structural items have been performed to date to ensure their adequacy. This review is further detailed in Section II.D below.
We recognize the industry concern that manufacturers of seismically sensitive electrical equipment may have modified their designs without knowledge of the nuclear requirements for seismic qualification. Attachment 2 of Table 12 (Page 34) identifies such items and provides our evaluation and our plan of action for further review of each item for acceptability in its seismic application.
A. Basis and Criteria for Rev[ew i The Basis for the Time Interval of the review is contained in Appendix A. The General Criteria for the Installed Items Review is contained in Appendix B.
B. Installed Items Review A review of commercial grade items warehouse issued from January 1, 1986 through November 1988 was conducted to identify installed items and to assess the effects on safety-related structures, systems, or components (systems) ability to perform safety-related functions. The Installed Items Review is the appropriate approach to justifying operability of systems based on the conclusions of the reviews conducted on data from Performance Monitoring / Event Analysis and for Procedures and Practices.
The Performance Monitoring / Event Analysis Review demonstrates the absence of identified trends that relate directly to items that failed, solely because they were purchased commercial grado. The Procedures and practices Review demonstrates that sufficient measures are in effect for the duration of this JC0 for ongoing purchases.
The major actions conducted by this raview are as follows:
1
- 1. Determining what items were purchased commercial stade and
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issued for use by consulting the Warehouse Transaction Log. J
- 2. Consulting the Maintenance Request (MR) Log to determine whi c h items were used in safety-related applications.
1 JCO 88-15, Rev. 1 i Page 2 of 71 Trojan Excellence- Our Way of Doing Business
Podland G:n ral El:ctric Nucl2ar Division Distribution February 17, 1989 page 3
- 3. Assessing the adequacy of the item to serve the requirements for operability in the safety-related application.
The detailed outline approach to the installed items review is provided as follows: 1
- 1. A sort on the Warehouse Transaction Log was obtained to list those items that were purchased with the procurement Code C or C1 and subsequently issued for use for the time interval 1986 through 1988. The Code C or C1 is a designation for procurement classification which is defined by Nuc1 car Division procedure (NDP) 300-1, " procurement Quality Level Classification System. Items purchased Code C or C1 have been the focus of the inspector's attention in the subject deficiencies. Code C or C1 represent items that are purchased from an unapproved supplier and accepted for use in safety-related-applications. The data fields utilized in the warehouse sort included Material Type, Description, Issue Code, and Maintenance Request.
- 2. A sort on the Maintenance Request Log was obtained to list thos'e Maintenance Requests that were treated as safety-related.
- 3. Based on an initial review of the Warehouse Transaction Log, each Material Type was identified and listed in Table 6.
- 4. The Material Type List was then sorted and refined as follows:
- a. The Material Types that relate to applications I designated quality-related but not safety-related were removed in accordance with the criteria contained in Appendix C. These Material Types are listed in Table 7.
- b. The Material Types that are incidental to plant functional requirements were removed in accordance with ;
the criteria contained in Appendix D. These Material Types are listed in Table 8.
- c. The remaining Material Types were divided into two categories:
(1) Electrical Material Typcs which are listed in Table 9.
(2) Mechanical / Civil Material Types which are listed in Table 10.
JC0 88-15, Rev. 1 page 3 of 71 Trojan Excellence- Our Way of Doing Business
. Portland G:n ra' Electric Nuclear Division Distribution February- l', .1989 Page 4
- 5. For each group of Electrical and Mechanical / Civil Material Types with similar requirements and characteristics, a technical evaluation was prepared. The technical evaluation for Electrical Material Types are contained in Appendix E. The technical evaluation for' Mechanical / Civil items are listed as Mechanical Material Types and are contained in Appendix F. The technical evaluation is provided to address the requirements and. characteristics that are specific to a group of Material Types. The technical evaluation brings attention to any special considerations or concerns such as environmental and seismic equipment qualification, pressure codes, and supporting structures as well as any special service requirements. Also, the technical evaluation establishes the adequacy of items in its installed application as meeting its respective functional requirements except when noted in Step II.D.8. The adequacy of the items are established by demonstrating how plant inspections and testing programs (eg, installation checks, preservice test, return-to-service function test, in-service inspection, )
etc) meet these requirements.
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- 6. An in-depth review was conducted of the items listed in the Warehouse Transaction Log for the Electrical and Mechanical Material Types (Table 9 and 10) in conjunction with the Maintenance Request Log to assess the adequacy of each item as it pertains to the applicable technical evaluation.
- 7. The in-depth review was accomplished by a task group of engineers. representing engineering disciplines in electrical, mechanical, civil, plant design, materials, equipment qualification, and systems operations. This task group surveyed the complete Warehouse Transaction Log to account for each' item and its respective use aa indicated in the Maintenance Request. The task group utilized a copy of the Warehouse Transaction Log as a work record to facilitate accountability and management of information.
The Warehouse Transaction Log contained the record for warehouse issue of parts requisitioned by a Purchase Requisition, Materials Stores Request, stock reorder, or local purchase.
The in-depth review required retrieval of numerous work request packages, procurement files, and design records.
The task group confirmed the adequacy of each item to function by verifying the applicability to the respective technical evaluation, thus justifying the operability for that item.
JC0 88-15, Rev. I page 4 of 71 Trojan Excellence - Our Way of Doing Business
Portland G:n ral Electric Nuclear Division Distribution February 17, 1989 Page 5
- 8. For those items where there remained additional concerns that are not satisfied by the technical evaluations, further actions / reviews were performed to justify operability. A summary of these concerns and resolutions is contained in Table 12.
- 9. A general summary of the actual applications and quantities of items found is contained in Table 11.
The installed items were found to be adequate for operability based on this review.
The present program for the procurement of new and replacement items in EQ applications is procedurally controlled by Nuclear Division Procedures (NDP 300-series),
Nuclear Plant Engineering Procedures (NPEP 200-21), and the Plant Operating Manual (AO-T-25). All require that EQ components be purchased from a vendor (QA code Al or D1) whose QA program has been audited by PCE or a PGE approved.
audit by another organization (eg, CASE, another utility).
In the.latter case, PGE performs periodic audits to confirm the vendor's QA performance. Certain subcomponents were allowed to be purchased commercial-grade with stringent requirements, but no commercial-grade items were found to be installed in applications which affect harsh-environment EQ, based on a review of the warehouse commercial-grade materials issued from January 1986 through November 1988.
C. Procedures and Practices A review was conducted to determine the adequacy of programmatic measures (Procedures and Practices) as it relates to the purchase of items commercial grade. The summary of this review is contained in Table 5. The focus of the NRC Inspection (Attachment A, Reference 1) has been to identify a need for PGE to change its procedural approach in qualifying items purchased commercial grade. Thus, past procedures and practices were appropriately identified as a cause leading to the existing condition.
Table 5 contains a listing of Additional Programmatic Measures that have been instituted. These measures ensure that current practices for qualifying future items purchased commercial l grade remain consistent with the assumptions established for !
operability for the duration of this JCO.
l D. Data From Existing Performance Monitoring Programs A review was conducted using data, covering the years 1986 i through 1988, from the following existing performance monitoring programs. This review was conducted to determine JC0 88-15, Rev. 1 Page 5 of 71 Trojan Excellence - Our Way of Doing Business ]
- Ponland G:neral El ctric Nucl:ar Division Distribution
\ February 17, 1989 Page 6 l
what trends in equipment failures have been identified and reported for management attention and corrective action. The results of this review demonstrate that-the trends identified support the merits for conducting the Installed Items Reviews.
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- 1. Licensee Event Report The summary of the review of the Licensee Event Report is contained in Table 1. The summary shows one isolated failure, nonrepetitive, but no failure. trends.
- 2. Performance Monitoring and Events Analysis - Event Reports The summary of the review of Event Reports is contained in Table 2. The averary shows a multitude of equipment failures due to various programmatic, installation, personnel, and original equipment design causes. No significant trends or occurrences are identified that are strictly root cause related to commercial grade procurement. However, various segregation of failures clearly correlate to major nonconforming activities in which improvements are being implemented (eg, Motor-Operated Valve Actuator Test System (M0 VATS) program, fuse study, Spare Parts Equivalency Evaluation Requests i (SPEERS), torque switch replacements, snubber program, transmitter replacements, welding control, etc).
- 3. Nonconformance Report (NCR) Trending A review of semlannual NCR Tronding Reports was conducted.
The reports have identified errors in three plant categories; Personnel, Design, and Installation, as the major causes for nonconformances. Manufacturing Deficiencies and Equipment Failures represent a lesser population of nonconformances. Manufacturing Deficiencies generally represent deficiencies in the original equipment assembly. Equipment Failures were predominantly attributed to feedwater pipe erosion and snubber deterioration. The NCR Trend Reports reviewed, are itemized in Table 3.
- 4. In-service Inspection (ISI) Program A review was performed on the ISI activities conducted by the Surveillance and Test Engineering Group to determine where deficiencies have been identified that relate to hardware performance. A listing of ISI activities reviewed is contained in Table 4. Specific failure data as a result of ISI activities are placed into the NCR and Event Report process. No trend data as they relate to procured items are directly derived from the test group. However, each responsibic test group lead did demonstrate positive JC0 88-15, Rev. 1 Page 6 of 71 Trojan Excellence- Our Way of Doing Business
Portland General Electric -
Nuclear Division i Di::tribution l February 17, 1989 ,
-Page 7 measures for ensuring operability (eg, snubbers, welds, pump and valves, pipe, supports) against adverse effects of defective procured items.
1 III. JC0 Duration and Special Conditions NCAR P88-212 provides for timely resolution, as necessary, of the items described in the JCO. The response for this NCAR has been assigned to Nuclear Plant Engineering. Nuclear Plant Engineering has initiated an Action Plan (ANR-1319-88M) to conduct additional reviews as necessary and provide recommendations in a timely manner to address the concerns raised by the NCAR.
The Additional Programmatic Measures that are listed in Table 5, Procedures and Practices, shall apply as Special Conditions to this i JCO.
This Revision 1 to JC0 88-15 supersedes JC0 88-15 dated November 29, 1988 in its entirety and is now the JC0 of record.
A safety evaluation has been performed per NDP 100-5. It was determined that there are no unreviewed safety questions.
CONCURRENCE BY:
Wh Actich Engineer V dn General Manager,' ~
i j . ec ical Functions
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C1Mirman G/ eral Manager, Trojan Plant Review Board Manager Nuclear Plant Engineering t Su rv s r '
dfNM PRB Members Manager TNOB Nuclear Safety & Regulation TNP: POW ST OP 2:JCO 55430 JC0 88-15, Rev. 1 Page 7 of 71 Trojan Excellence- Our Way of Doing Business
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' ATTACHMENT'A.
REFERENCES
- 1. NRC Vendor Program Branch Inspection Report 50-344/85-025.
- 2. NRC Vendor Program Branch Inspection Report 50-344/85-38.
- 3. NRC Routine Inspection Report 50-344'88-39. /
- 4. -NRC Routine Inspection Report 50-344/88-46,
- 5. PGE Nonconforming Activities Report'(NU.2) P88-212.
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DM/55430 l
JC0 88-15, Rev. 1 Page 8 of 71
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ATTACHMENT B A safety evaluation was performed as required by NDP 100-5'and is on file
-separately, i
l WDF/55490 JC0 88-15, Rev. 1 Page 9 of 71 l.
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JCOs:
Shift Supervisor PRB Members. ]
TNOB Members R. C.'Rupe ]/
A. H. Miller !
'TNP: POW ST OP 2:JCO 1 l
TNOB:
D. W. Cockfield, Vice President C. P. Yundt, Chairman
.T. D. Walt, Vice Chairman Frewing
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A. N. Roller- ]
C. A. Olmstead L. W.-Erickson R. W. Celebe c: D. R. Swanson P. A. McMillan TNOB: ADMIN: Correspondence PRB:
D. W. Swan, Chairman P. A. Morton R. L. Russell D. L. Bennett T. O. Meek C. H. Brown c: S. W. Bowman
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1 DM/49380 JC0 88-15, Rev. 1 Page 10 of 71 J
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ATTACHMENT-D'
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JC0 DEVELOPMENT - CRITERIA AND RESULTS' f
Activity Results Review of Licensee Event Reports Table 1 1
-Review of Event' Reports Table'2 "
Review of NCR Trending Reports Table 3 Review of Inservice Inspection Program Table 4 l
~ Review of Procedures, Practices, and Additional Table 5 Programmatic Measuros
. Review of' Installed Itemc/ Materials Types Initial' Review Population Table 6' 'g
-Quality-Related But Not Safety-Related Table 7
-Incidentals Table 8 Electrical Items Table 9 Mechanical Items' Table 10 General Summary. . Table 11' Sample of Small-Bore Valves Applications . Attachment-1
- i Items for Special Resolution Table 12 0-Rings Attachment 1 Electric-Items witn Contacts Attachment-2 Criteria for Evaluation Appendix Selection of Time Interval Appendix A Cenoral Celteria for Installed Items Review Appendix B Criteria for Quality-Related Appendix C Critoria for Incidentals Appendix D Electrical Items Technical Evaluation Appendix E Mechanical Items Technical Evaluation Appendix F AHM/49390 JCO 88-15. Rev. 1 Page 11 of 71 m
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J NOTE: Equipment Failure-Related Licensee-Event Reports.
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TABLE 1
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Review Summary Licensee Event Reports' l
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l Licensee Event Reports (LERs) were reviewed using the following steps:
- 1. Licenseo Event Reports that were written from 1986 through 1988 were identified.
- 2. These identified Licensee Event Reports were then further sorted using the Cause Code classification.
Cause Code Failure Classification A Personnel Error B Design, Manuf acturing, Construction /
Installation C- External Cause, Natural Phenomena D Defective Procedure E Management / Quality Assurance Deficiency X Other
- 3. The LERs that may have been attributed to component failures (cause Coded B. E, and X) were selected for further review to determine if the failures were related to the commercial grado purchase of parts.
The following list shows the LER number, event date, description /
cause summary, and whether or not it was directly related to items purchased commercial grade.
49240 l
JC0 88-15, Rev. 1 Page 12 of 71
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NOTE: ' Event Reporte Selected by'the Manager of Performance Monitoring Event Analysis for
-review to determine failure causes due to items purchased commercial grade.
TABLE 2 Page 1 of 3 Review Summary - Event Roports The following is a summary of reviews performed on Event Reports. These Event Reports were identified by the Manager of Performance Monitoring / Event Analysis as events of interest with the potential of'being related to parts purchased commercial grade. An entry for operability significance is provided -
only if the failure mode is directly attributed to an item purchased ;
Event Operability Report Failure Cause Significance 88-064 Valves:(Leaks)- Equivalency Evaluation
'N/A 88-028. Safety Relief Valve Procedure N/A 88-003 Transistor Random / Aging Reactor Trip 87-199 Transmitter Setpoint Delft N/A 87-185 Motor-Operated Valve Limit Switch Settings N/A 87-176 Transmitter Setpoint Drift N/A 87-173 Motor-Operated Valve Design N/A (Wiring) 87-169- Transmitter Setpoint Drift N/A 87-166 Vendor Notice Original Equipment N/A 87-147 Valves (Leakage) Equivalency Evaluation N/A 87-141 Radiation Monitor Design N/A 87-123 Welds Procedure N/A l 87-117 Solenoid Valve Installation N/A 87-103 Hose Fitting Personnel N/A JC0 88-15. Rev. 1 Page 14 of 71
I TABLE 2 (Continued) Page 2 of 3 .)
Event Operability Report Failure Cause Significance 87-097 Nameplates (Missing) Origina:1 Equipment N/A 87-084 Wolds Procedure N/A 87-073 Limit Switch (Crack) Original Equipment N/A 87-063 AFW Dierol Grommet Equivalency Evaluation N/A 87-062 Torque Switch Original Equipment N/A 87-056 Stems Bent Original Equipment N/A 87-053 Break Coil Original Equipment N/A 87-051 Control Valve (Leak) Housekeeping N/A 87-050 Motor-Operated Valve Torque Switch Setting N/A 87-049 Torque Switch Original Equipment N/A l 87-048 Inservice Inspection Design N/A Missed 87-047 Motor-Operated Valve Torque Switch Setting N/A 87-046 Motor-Operated Valve Torque Switch Setting N/A 87-045 Observations Personnel N/A 87-042 Spring Pack original Equipmt;t N/A 87-040 Torque Switch Wiring Design N/A 87-035 Rollef Valve Setpoint Drift N/A !87-034 CV Limit Switch Damage N/A 87-031 Inservice Inspection Code Misinterpretation N/A Missed 87-025 Fuse Workmanship N/A 87-019 Flow Control Valve NRC Notice 87-01 h/A 87-013 Steam Trap Procedure N/A 87-009 Motor-Operated Valve Design N/A 86-138 Valve (Undertorqued) Personnel N/A JC0 88-15. Rev. 1 Page 15 of 71
TABLE 2 (C'ontinued) Page 3 of 3 Event. Operability Report Failure Cause Significance 86-129 Fire Barrier Design N/A 86-119 Pressure-Operated Relief Personnel N/A Valve 86-104 Panel Clips (Missing) Original Equipment N/A 1
86-098 Electrical Tape Workmanship N/A i 86-097 Rad Monitor Procedure N/A 86-096 QA Audit Limitorque Removed from ECSL 86-093 Capacitor Original Equipment N/A 86-083 Snubber Design N/A 86-067 Chemistry Procedure N/A 86-063 QA Documentation Procedure N/A 86-040 Time Delay Relay Design N/A 86-033 Control Valve Limit Switch Setting N/A (Indication)86-014 Motor-Operated Valve Original Equipment N/A (Wire Insulation)86-012 Motor-operated Valve Original Equipment N/A (Loose Wire)86-009 Fuse Equivalency Evaluallon N/A 86-007 Motor-operated Valvo Original Equipment N/A LS/49260 JCO 88-15. Rev. 1 Page 16 of 71
NOTE: Semiannual NCR Trending Reports provided by Quality Services for all NCR Trend Categories TABLE 3 Review Summary 'NCR Trending Reports NCR' Trending Reports are issued semiannually by the Quality Services staff in accordance with the requirements of NDP 600-1, " Control of Nonconforming Materials, Parts'and Components". The review was ,
conducted on the following NCR. Trend Reports:
Report Issue Letter Report Covers NCR Issuo Dates Date Number From To 09/01/88 LWE-329-88 January 1988 June 1988 02/23/88 LWE-49-88 .uly 1987 December 1987 08/27/87 RCJ-322-87 January 1987 June 1987 02/13/87 RCJ-11-87 July 1986 December 1986 08/29/86 CAO-360-86 January 1986 June 1986 i
LS/49250 JC0 88-15, Rev. 1 Pago 17 of 71
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NOTE: _ Inservice Inspection Activities Which are tracked, and reviewed by the
,- Surveillance and Test Engineering Group-l TABLE 4 Review Summary - Inservice Inspection Group
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A review of the Inservice Inspection (ISI) activities performed by the Surveillance and Test Engineering Group was_ conducted. .A summary of. activities performed for specific items is outlined below:
Snubbers The Snubber Test Engineer ensures that all snubber parts are purchased Code D1 (non-Commercial Grade). The Snubber Group Lead is cognizant of all plant activities affecting snubbers and maintains a snuboer activity report to track and account for each activity.
Pump and Valve Program The Pump and Valve Test Engineer tracks and monitors successful operability tests on pumps and valves.
Piping and Supports Piping is hydro and pressure tested as appropriate for preservice and inservice surveillance. Supports are inservice inspected for deformation and cracks.
Welds This ISI Computer (ISIC) Surveillance Tracking Program identifies every weld for the specific Nondestructive Examination (NDE) and visual inspections for preservice and inservice surveillance. The ISI Test Engineer utilizes the ISIC program to track the satisfactory completion of the required preservice and inservice activity. <
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DM/49310 JCO 88-15 Rev. 1 Page 18 of 71
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h4 NOTE: Procedures and Practices which relate to-the L . adequacy of purchasing: items commercial grade.
[i ~ Additional' Programmatic Neasures applicable to.the
~JCO Special Conditions.-
TABLE 5= Page 1 of 2 1
Review Summary' Procedures and Practices.
In July 1986, PCE implemented a set of new NDP 300 Series Procurement
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Procedures. The new procedures established ~ a new format for classifying purchases and were intended to better define activities. associated with engineering evaluations and qualification verification. However,.the effectiveness of theLprocedures to enforce procurement activities.in.
compliance with regulatory commitments has since been determined less-than adequate. [1]-[2]'[3] [4]
In recognizing the impetus of-these deficiencies, various PCE organiza-tions have gradually instituted: improved practices.to effect the adequacy-and controls on items purchased commercial grade'. ' Improved practices
- that warrant summarizing in this JC0 are those implemented within.the
~
Materials Department.
Practices'in the Materials Department. Recent Changes
' The-department was reorganized to allow focus on three Materials activi-ties, each with'a separate supervisor. Further changes in practices are:
outlined below.
Receiving: This group was geographically relocated to the Pebble Springs warehouse to separate receiving activities from normal warehousing to allow for better utilization of space in the main warehouse as well as more effective use of the inspector's time.
Recently, a program was created to identify deficiencies at.the receipt dock. The following two documents are a result of this program:
- 1. Hardware Deficiency Notice (HDN)
I
- 2. Documentation Deficiency Notice (DDN)
Increase emphasis in the Quality Control practices include:
Independent Quality Control interface Quality control Training
, Implementation of non-destructive examinations on appropriate items (ie, fasteners, pipe, structural steel) .
Warehousing: Inventory analysts were added to the group to optimize usability of the items stocked eg, elimination of numerous items with indeterminate' intended use.
JC0 88-15, Rev. 1 Page 19 of 71
l TABLE 5 (Continued) Page 2 of 2 Procuremetit Engineering: A procurement. engineering staff has been established.
Additional Programmatic Measures The following programmatic measures have been established concerning the control'and inspection of items purchased commercial grade'.
- 1. Nuclear Division' memorandum dated October 28, 1988-(ANH-1093-88M),
requires that materials ordered for pressure piping and supports be ordered Procurement Code Dl. Materials may be ordered Code C1 if certified by PGE.
- 2. Non-Destructive Examinations (NDEs) at receipt have been' established by' practice. The NDE practices began following the response to IEB 87-02, which'related to the examination of fasteners. Sampling.
and test plans are in development.
- 3. Materials memorandum dated November 1, 1988 (MDG-08-88). All~
material requests for small-bore piping systems (eg, pipe and fittings loss than 1 inch, attachments, hangers, supports, and.
fasteners)'shall be approved by a mechanical procurement engineer.
- 4. Materials memorandum dated November 28, 1988 (JMA-94-88). All procurement Quality Codes C1, D and C items shall be approved by a procurement engineer prior to issue from warehouse, effective immediately.
I
(~ DM/49320 I
l JCO 88-15, Rev. 1 Page 20 of 71
I u
NOTE: 'This table consists of a list of Material Types
'taken from the Warehouse Transaction' Log..which was sorted by Code C and C1 and subsequently issued for use.
TABLE 6 Page 1 of 2 Material Types Initial Review Results Abrasive Electrode Actuator Engine Part
~ Adapter Fan Adhesive Filters; 011, Air, Cas Amplifier Fire Equipment Analyzer- Framing Steel:
Anchor Unistrut, Capscrew, Anchor. Bolt Beam Clamp, Flat Plate, Anode SQ Washer, U-Shape. Fittings Battery Spring Nut, Channel Bracket Bearing Fuse i Belt Gaskets Bistable Cauge; Pressure, Temperature Board Assembly- Gauges Bolt Gears Box; Terminal , Switch Glass Sheet Bracket Hardware; Door Cable Heat Trace Cable Tie Heater; O/L, Exchanger Cap Hose; Connector Time Capacitor Indicator Cartridge Filter Insulation Cell Insulation; Cable, Pipe Chain Integrated Circuit Chart Paper Jack; Phone Chemical Janitorial Supplies Clamp; Pipe, Beam Key Stock Coll; Misc, Solenoid Kit; Seal, Cable Prep Compressor Part Lamps; Holder, Lens Computer Lens Condult; Fitting Lockwire Condult; Hanger Lubricant Connector; Wire T/C Lug; Terminal Contactor; Misc, Block MCC Part Container Meter Coupling Misc I&C, Camera Parts Crane Parts Module, Hagan, I/V l Cylinder Monitor; Security, Seismic l Detector Motor; Servo j l Diaphragm Nuts, Bolts, U-bolts, Washers l Diodo 0-Rings JC0 88-15 Rev. 1 Page 21 of 71 i
m_ _ _ _ _ _m___________ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
I TABLE 6.(Continued) .Page 2'cf'2- z l
I Office Supply Steam Traps .)
Orifice Stock Teflon Rod /
Packings Strainer Paint Structural Steel:
Pins: Hinge, Cotter, Cam Flat Bar Pipe .
Angle 'I Pipe' Fittings. Round Plexiglas' I-Beam f
. Plug; Electric Square Tube Printed Circuit Board Channel.
Probes Plate Pump Parts Threaded Rods l!
RTD . Swagelok Fittings Rad Monitor Part Switch Reactor-Stud Tensioner Tachometer Rebar- Tape; Magnetic, Electric Recorder Part Terr 8.nal Block i Regulator;' Air Thermocouple Relay; O/L, Protective, Logic Thermometer Resistor; Fixed, Variable Thermowell Respirator Part .
Thyristor
-Ring; Wear, Snap, Retaining Timer; Sampling Screen Tool Screws Transducer Seal Oil Transistor Seal; Dies:el AFW - Transmitter; Part Sealant; Crout, Silicon Tube; GM, Rad Mon Seals . Tubing Clamps Security Tubing; Copper, SS, Tygon Shim Stock Tubing flydrogen Cas, copper Sleeve Turbino Snubber Parts Valve Parts Solenoid Valves Solvent Welding Rod Springs Welding Supplies Sprocket Wire; Switchboard LS/49230
^
JC0 88-15, Rey, 1 Page 22 of 71
i NOTE: This table contains a list of Material Types .
that are quality-related, but not safety-related per the criteria in Appendix C.
TABLE 7 Naterial Types - Designated Quality-Related. But Not Safety-Related
+ Security Monitors, Cameras
~
+ Seismic Recorder Parts
- Crane Parts (nonload bearing)
+ Hoisting, Slings, Chains
- Door Hardware
- Fire Equipment
- Tools, Probes !
+ Area Radiation Monitoring Parts
- Container
+ Thermometer 49070 JC0 88-15, Rev. 1 Pago 23 of 71
t, L NOTE:- This table contains a list of Material Types that are incidental to plant functional requirements'per the criteria in Appendix D.
l TABLE 8 Material Types - Incidental to Plant Functional Requirements-Based upon the criteria and conditions stated under Operational and Maintenance Support Supplies and Items Required for Normal Plant Operations, the following items have been designated as incidental to plant functional requirements.
+ Abrasives + Lapping Compound
+ Adhesive + Lockwire
+ Air Compressor Parts
- Magnetic Tape
+ Belts + Miscellaneous Paint
- Cable Tie + Office Supplies
+ Caps + Packing
+ Chart Paper
- Phone Jack
+ Chemicals
- Pipe Insulation
- Computers
- Plexiglas
+ Conduit and Fittings + Pull Boxes
- Respirator
+ Extension Cords
- Sealant
+ Filters + Shim Stock
+ Flashlight Batteries
- Solvents
- Caskets
- Strainers
- Cauges
- Teflon Tubing
+ Class Sheet + Thread Lubricant
+ Janitoral Supplies + Tie Wraps
- Lamps and Lens )
49090 '
JC0 88-15, Rev. 1 Page 24 of 71 2
'b u
HOTE: This table consists of' Electrical Material Types-
, that are used in safety-related' applications. 1
' TABLE 9 j Material Types - Electrical:
Actuator. Lubricant
! Amplifier- Lug;. Terminal Analyzer Meter Anchor Module; Hagan, Controller JAnode Motor; Servo Battery 0-Ring-
. Bistable Printed Circuit Board. ;
Board Assembly. Probes L Box; Terminal , Switch "
Radiation Monitor Part-Cable Relay; Overload, Protective, Logic, Time Capacitor Resistor; Fixed, Variable Cartridge Filter Resistance Temperature Detector (RTD):
i cell ' '
Sealant.
Coll; Misc Solenoid. Sleeve Connector; Wire, Thermocouple Solenoid-Contactor; Misc, Block- Switch Coupling Tachometer
' Detector Tape; Electric- ,e Diaphragm: Terminal Block Diode- Timer; Sampling Electrode Thermocouple Fuse Transducer Heater; Overload, Exchanger Transistor Heat Trace Transmitter; Part Indicator Tube; Ceiger Muller, Rad Mon Integrated Circuit Thyristor Kit; Seal, Cable Prep Tubing; Hydrogen Cas, Copper Lamps; Holder, Lens Wire; Switchboard Motor Control Center (MCC) Part LS/49080 JC0 88-15. Rev. 1 Pago 25 of 71
NOTE: This table consists of Mechanical Material Types that are used in safety-related applications.
\
TABLE 10 Material Typos - Mechanical / Civil Anchor Bolt Bearings ,
Condult; Hanger Fittings Diaphragm Engine Parts Framing Steel:
Unistrut, Capscrew, Beam Clamp Flat Plate, SQ Washer, U-Shape, Fitting, Spring Nuts, Channel 3 racket Gaskets Gears Insulation Nuts, Bolts, U-Bolts, Wasbers 0-Rings Packings Pins; Hinge, Cotter, Cam Pipe Pipe Fittings Pump Parts Rebar Ring; Wear, Snap, Retaining Screen Screws Seal Oil Sealant; Grout Seals Snubber Parts Springs Steam Traps Strainer Structural Steel Flat Bar, Angle, Round, I-Beam, Square Tube, Channel Plate, Threaded Rods Swagelok Fittings Tubing Clamps Tubing; Copper, Stainless Steel Turbine Valve Parts Valves Welding Rod LS/49200 JC0 88-15, Rev. 1 Page 26 of 71
O in f.
1 NOTE:- This table contains a general summary of-the.
Items issued for used: .(1) applications and D (2) quantitles.
- _ TABLE 11 General Summary of Items Found
- The Quantity of Warehouse Transaction Log line items is approximately 20,000.
- Approximately 70' percent of the.line items were' determined to have been used only in quality-related systems or non-safety-related-applications.
- No' full equipment assemblies (eg, MCCs, snubbers, switchgear, transmitters, pumps, large-bore valves, etc) were issued for safety-related applications.
- Predominantly, items used in safety-related applications were simple in terms of requirements and checks.
a .There were many fasteners, anchors, and structural steel items.
- There were no snubber parts used in safety-related applications.
- There were 40 diesel parts relating to Emergency Diesel Generator (EDC) and Auxiliary Feedwater (AFW). These parts were simple in kind.
- There were 200 small-bore valves of which none were installed as a primary pressure boundary item as evidanced by the sample attached to this table. Also, or.iy a small portion of these valves are installed in safoty-relots ? systems. Most of these valves are used in various miscellaneous ways that related to normal system operation or maintenance support.
- There were 10 subassembly items for large valves (eg, hinge pins and seal rings) that were used in safety-related applications.
DH/49330 JC0 88-15. Rev. 1 Page 27 of 71
= - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ . _ ._. _ _ - - _ _ _ _ _ -
ATTACHMENT 1 0F TABLE ll Page 1 of 2 Valves 2-1/2-Inch and Less - Sampling Review for RCS Pressure Boundary Items This tabulation represents a random sample of 20 valves 2-1/2 inch or less, out of an or!.ginal population of 200, to demonstrate that commercially procured valves of this type are not utilized in RCS pressure bounding applicationte.
The generic. evaluation of small-bore valves is evaluation M-6 of Appendix F.
Description from MR,(g& if Safety- or Ouality-Related Status
- 1. Resin Discharge Hose in Fuel Building Bay - Hook-up Non-Safety-Related discharge and pressure test.
- 2. Installed with a non-safety-related or non-quality- Non-Safety-Related related MR.
- 3. EDG Engine Oil Return Line - Check valve leaks. Not RCS pressure baundary
- 4. S/G Blowdown Filter Vent - Operations nut is loose Not RCS pressure from valve assembly, boundary
- 5. Installed with a ntn-safety-related or non-quality- Non-Safety-Related related MR.
- 7. Control Room Emergency Vent Chillers - Air leak Not RCS pressure through uncapped vent line. boundary
- 8. Installed with a non-safety-related or non-quality- Non-Safety-Related related MR.
- 9. Potable Water Pipe - Leak in pipe near security Non-Safety-Related trailer.
- 10. Fire Hydrant - Gate Valve is cracked. Non-Safety-Related
- 11. Valves in H2 Sample Panel - Valves leak by the seat. Not RCS precsure boundary
- 12. Diesel Fire Pump Actuating Switch - Change Setpoint Non-Safety-Related per PSC 86-02.
- 13. SWS Supply to SI Pump B - Supply valves are Not RCS pressure defective, boundary JC0 88-15, Rev. 1 Page 28 of 71
ATTACHMENT'1 OF TABLE 11 Page 2'of.2-
. Description from NR Loa if Safety- or'Ouality-Related. Status
- 14. PT-143, 61-FL Pipe Facade --Leaking valve packing Not RCS pressure L and fitting. ' boundary
- 15. No l Deluge: System Strainer Drain Valve - Strainer Non-Safety-Related drain valve leaks.
- 16. Installed with a non-safety-related or non-quality- Non-Safety-Related related NR.
- 17. Various Piping Systems - Provide support for ISI. Non-Safety-Related ,
- 18. VE-160B Outlet Throttle Valve - Leaks by seat. Not RCS pressure boundaryf
- 19. CCP Room Cooler Outlet Valve - Through-wall leakage. .Non-Safety-Related'
- 20. A Waste Cas Compressor - Oil leak under compressor- Non-Safety-Related head.
RCS: Reactor Coolant System NOTE: Reactor coolant system boundary small bore valves are distinguished from other small-born valves by the need for the Design Stress Report required for the RCS valves. The design for small bore valves in other piping system applications are based solely on the manufacturer's product design ratings.
c DM/49330 JCO 88-15, Rev. 1 Page 29 of 71
.t .
NOTE: This table contains an evaluation that resolves additional concerns that are not addressed in the Technical Evaluation TABLE 12 Installed Items That Required' Special Attention for Resolution Two types of installed items required additional action / review to justify operability.
- 1. 0-rings
- 2. Electric items with contacte.
A summary of.each is attached to this table.
l DM/49340 l
JC0 88-15 Rev. 1 Page 30 of 71
1 i
1 !
l ATTACHMENT 1 0F TABLE 12 Page 1 of 3 0-Rinr,s Additional Concern Based on a review of the 0-ring applications, it was determined that after elimination of those associated with non-safety-listed components, the following equipment categories contained items requiring further.
review. The addillonal review was required due to the diversified makes and uses of 0-rings, some of which are used in harsh environments.
- 1. Pumps
- 2. Valves i
- 3. Instrumentation
- 4. Filters / strainers
- 5. Diesel Generators These categories are tabulated on the attached sheets, with a total of 32 components reviewed.
Action and Results The above categories were screened for environmental location (harsh versus mild) to further eliminate components of concern. This screen resulted in three components located in harsh environments as follows:
P202A - RHR Pump A l P205A - Centrifugal Charging Pump !
MOV3346 - Component Cooling Water System The procurement procuss of 0-rings for theso three components is considered adequate for the following reasons:
- 1. In the case of the pumps (P202A and P205A), the 0-rings were supplied from the original equipment manufacturer.
- 2. In the case of the Limitorque operator quad 0-ring on MOV3346, this item does not perform a safety-related function. This is based on the fact that the actuator is designed and qualified to operate on the loss of gaskets and seals.
JC0 88-15, Rev. 1 Page 31 of 71
.,[.,
~
ATTACHMENT 1 OF TABLE 12 >.Page[2~of'3
- l l
Equipment System ' Environment System Description'
~
1 Pumps P201A 'Not'EQML .On motor.
P211A' 'Not EQML. .On motor P211B- Not-EQML On motor
.P202A** RHR Harsh RHR P148C SW- Exempt Service Water
,CC213 Not EQML On motor-CC214 Not EQML On motor P102B Not EQML .On' motor P205A** CVCS -Harsh. Centrifugal Charging Pumps <
P106A .Not EQML On motor P106B : Not EQML On motor P108A SW MildJ Service Water Valves CV1452, Not EQML CV1453 Not.EQML CV81680 Not EQML CV2280 Not EQML 8278 .Not EQML CV2297 Not EQML CV2295- Not.EQML CV8032 Not EQML CV3287 Not EQML MOV3346* CCW- Harsh Component Cooling Water SB3239. CCW (A216) Component Cooling Water Instruments UR2087B Not EQML LT258 Not EQML LT957 Not EQML LT950 Not EQML Strainers F205A,B Not EQML F101A Not EQML
- Non-Safety-Related part; not required for operation / qualification.
- Procurement of 0-ring was made f rom original equipment L . manufacturer.
H 4 Not EQML: Not an Environmental Qualification Master List component. '
, JC0 88-15, Rev. 1 Page 32 of 71
- - - - _ _ _ - = ______ _ - .
L
.J ';
ATTACHMENT l'0F TABLE 12 Page 3'of,3 Equipment _ System Environment Description Diesels K107B EDG- ' Mild AFW Diesel
-K106A EDC ' Mild Emergency Diesel Generator K106B- EDG Mild Emergency Diesel Generator-DM/49340 JC0 88-15, Rev. 1 Page 33 of 71 2____________________________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ ___ _ _ . - _ _ . _ _ _ _ _ _ _ __ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _
i i
ATTACHMENT 2 OF TABLE 12 Page 1 of 6 j 1
l l Electrical Items With contacts ]
I
! l Additional Concern j l
Commercially procured electromechanical items with movable contacts have '
received additional review as part of the operability verification evaluation. The concern warranting review is the possibility and effects of contact chatter or spurious actuation on logic and/or control functions as a result of seismic motion. At Trojan, replacement cmponents required to remain operable or structurally intact during a .
seismic event receive a seismic review prior to installation. This I review is based on similarity to a qualified unit either through the Request For Design Change (RDC) process for modifications, or the Spare 1 Parts Equivalency Evaluation Report (SPEER) process for item l substitution. The procedures governing these two activities are !
NDP-200-1, " Design Change Control", and Administrative Order A0-5-3,
" Spare Parts Equivalency Evaluation Report". Like-in-Pind replacements are considered qualified in accordance with the standards applicable to the original equipment and to the qualification reports of the originally qualified equipment. Operability, spurious actuation, and contact !
chatter are considered during the seismic review.
An additional review has been undertaken of electromechanical C and C1 items with movable contacts issued potentially for safety-related applications, to substantiate the like-for-like reviews conducted during acceptance. The following are categories of item types meriting this review:
Category Quantity Issued
- 1. Relays (Auxiliary, Overload, Time Delay) 35
- 2. Contactors 5
- 3. Circuit Breakers 20
- 4. Switches (Position, Limit, Pressure) 18 An initial review of these items was conducted using the following methodology:
- 1. Items were initially screened using the Maintenance Request Log to eliminate those items cicarly used in a non-safety-related '
application from further review.
- 2. Items which remained in the population were then reviewed using the Maintenance Request to determine if the end use is safety related. J
{
Forty-nine of these items from Steps 1 and 2 were issued for non-safety-related applications and were eliminated from further
]
j review. i l
JC0 83-15, Rev. 1 Page 34 of 71 i l
l J
Attachment 2 Page 2 of 6 The items which merited additional review after this first survey are tabulated by category on the following pages.
- 3. A carnle of installed items was then examined to determine those that were used in a nonseismically affected control function, eg, annunciation and valve position indication. Items of this type, such as Component Cooling Water tank relief valve position switches, can tolerate contact chattor during a seismic event without loss of function. For the safety functions that were examined, it was demonstrated that with a closer examination on the not effects of contact chatter and spurious operation, a larger percentage of installed items of concern are eliminated.
During this review, three additional devices were found to be either not used or returned to stock, and are indicated in the tables.
To substantiate the like-for-like reviews conducted on the remaining 26 qualified items, all will be evaluated in detail and to the extent necessary to determine that the items' seismic performance characteristics have not changed. This review will involve establishing the design configuration of the originally tested and qualified unit from plant and vendor documentation, and comparing it directly with the design configuration of the installed unit. This review will identify and evaluate any changes in design that could impact the required seismic performance. Nonconforming or indeterminate items will be tested or replaced and dispositioned through the Nonconformance Reporting (NCR) process.
Nuclear Plant Engineering will supervise the timely intpection, evaluation, and resolution of this review. This activity has been identified for and will be tracked through the Nuclear Plant Engineering Action Plan on Commercial Grade Materials, ANR-1319-88M.
These items are considered operable based on their initial seismic review and qualification and the PGE former standard practice of replacing items utilizing the same or equivalent manufacturer and part/model number. This additional review and evaluation conducted under the referenced Action Plan serves to confirm the initial conclusions.
AHM/49280 JCO 88-15, Rev. 1 Page 35 of 71
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[ a l NOTE: This appendix contains the basis for selecting and justifying the Time Interval for reviewing:
- l. Data from Performance Monitoring l- Procedures and Practices Installed Items APPENDIX A BASIS FOR REVIEW TIME INTERVAL
-The Time Interval for.the review used in this JC0 is January 1,11986 through November 1988. This time is based on the following:
- 1. This Time Interval was selected to be consistent with the interval when the inspection corrective action process began for the specific deficiencies identified.
- 2. The Time Interval established is reasonable and sufficient provided actual defects and nonconforming items affecting operability, pertaining to the two deficiencies noted in Section I, are absent.
- 3. The Time Interval represents a significant service history for items that have been installed.
- 4. The Time Interval for performance monitoring is conservative in representing trends on items installed prior to January 1, 1986.
- 5. The implementation of new programs (ag, the Environmental Qualification Program, MOVATS, Fuse Study, Snubbec Surveillance and Test Program, etc) provides the principal means of assessing operability of installed equipment. The importance of the data provided by these programs increases with time, thus making the records for the checks during initial procurement relatively less significant.
- 6. No defective items related to a commercial grade procurement have been uncovered for the time interval selected. Had failure items i been discovered, then a revision to the time interval selected would have been considered.
LS/49210 l
,1 JC0 88-15, Rev. 1 Page 40 of 71
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l NOTE: This appendix contains the general criteria for determining the functional characteristics used !
-in the Installed Items Review. 'l i
Page 1 of 3 i
APPENDIX B ,
i General Criteria-for Installed Items Review -
The following General Criteria are provided to demonstrate a perspective between Material Types as it relates to their functional characteristics and the appropriate approach for inspection and testing.
Plant Punctional Requirements All service, design, and qualification requirements for an item to perform a safety-related function, Simple Commodities The following items must satisfy plant functional requirements.
These items have simple critical characteristics which are ordinarily controlled by a broad multi-industry commodities market. Simple checks at receipt and installation usually serve in assuring the adequacy of these items.
- Bearings
- Copper Tubing
+ Key Stock
+ Lubricants
- Pins
- Screws <1/4 inch i
+ Threaded Rods JC0 88-15, Rev. 1 Page 41 of 71
l: APPENDIX B (Continued) Page 2 of 3 l
General Criteria for Installed Items Review Product Pre-Engineered Items The following items must satisfy plant functional requirements. These items are designed and manufactured to a product catalog specification and prototype tested to meet specified physical and performance charac-teristics. These items are (1) selected based upon the suitability of the item as specified to satisfy functional requirements, and (2) usually accepted for use based upon a survey of vendor effectiveness to certify items in accordance to product specifications represented by a unique product identifier.
In lieu of the vendor survey, the plant may exercise checks (eg, nondestructive examinations, installation checks, functional tests, etc) to verify characteristics that are critical to plant functional requirements.
- Circuit Breakers
- Relays
+ Coatings + Small Valves, Small-Bore Pipe
- Electronics + Snubbers
- Engine Parts (simple) + Swagelok Fittings, Instrument Tubing
- Fasteners
- Transmitters
+ Grout + U-Bolts
+ lleat Shrink + Unistrut
+ Limit Switches + Wedge Anchors
+ O-Rings, Seals, Gaskets + Weld Rod
+ Pipe and Conduit Clamps
- Wire Connectors
+ Pump and Valve Parts (non-pressure retaining)
JC0 88-15, Rev. 1 Page 42 of 71 l
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APPENDIX B (Continued) Page 3 of 3 General Criteria for Installed Items Review Plant Specified Items The following items must~ satisfy plant functional requirements. The items are designed and manufactured to a specification uniquely prepared to satisfy plant functional requirements. These items should be pur-chased from an approved supplier who has demonstrated rigorous verifi-
- cation activities appropriate for complex design and manufacturing c _-
processes.
+ Large-Bore Pipe and Fittings
+ Large Bore Pumps and Valves (Major Subassembly Items)
+ Structural Steel
+ Engine Parts (Major Subassembly Items) i I
DM/49050 l
l JC0 88-15, Rev. 1 Page 43 of 71
(N NOTE: This appendix contains the criteria'for determining which Material Types are used in zquality-related applications, but not in safety-related applications APPENDIX C Criteria - Material Types Designated Quality-Related. But Not Safety-Related Quality-Related Systems The following systems are characterized as quality-related but not safety-related, in accordance with the quality-related designations of NDP-300-1, Revision 1.
Environmental and Effluent Monitoring (except Regulatory Culde 1.97 Category 1 and 2 items)
. Standard Technical Specification Equipment List a
Fire Protection Equipment List
+ Security Equipment List
= Radiation Protection
- Packaging Radioactive Material for Transport-
- Emergency Planning
. Radioactive Waste Management Equipment List
- Post-Accident Monitoring
- Seismic II/I
= Anticipated Transients Without Scram Equipment
- Tool Control
- Cranes and Hoisting Components which affect these systems or parts of components which affect these systems are considered quality-related and not safety-related.
AltM/49050 JC0 88-15, Rev. 1 Page 44 of 71
i i
NOTE: lfhis appendix contains the criteria for determining i those: Material Types that are used only in applications incidental to plant safety functions.
- APPENDIX D t
~
Criteria - Material Types Incidental to Plant Functional Requirements Operational and Maintenance Support Supplies The following items are utilized in support of day-to-day maintenance and operational activities. -They are incidental to plant functional requirements, provided the usual controls established for hazardous materials,' housekeeping, and workmanship apply.
. Chemicals (non-boron)
+ class Sheet
- Janitorial Supplies
- Lapping Compound Miscellaneous Paint
+ Sealant.
+ Shim Stock
+ Thread Lubricant
' Items Required for Normal Plant Operation The following items are required only during normal systems operations.
They are incidental to plant functional requirements provided configura-tion controls during maintenance and design modifications apply.
- Chart Paper Coatings (outside containment)
- Filters
- Caskets
- Packing
+ Pipe Insulation
+ Strainers DM/49050 JC0 88-15, Rev. 1 Page 45 of 71
NOTE:' This appendix contains the Electrical Technical Evaluations used by the JCO Task Group Engineers for verifying the adequacy of installed items'in their respective applications APPENDIX E Electrical Technical Evaluation Technical evaluations applicable to the following electrical material
~
types are contained in this appendix.
Technical Evaluation Designation Applicable Material Types EE-1 Contact Blocks, Breaker Parts EE-2 Heat Shrink, Electrical Tape, Splice Kit EE-3 Cancelled EE-4 Fuses, Overload Heater Elements-EE-5 Electronic Subassembly Items
.EE-6 Limit Switch, Micro Switch, Selector Switch EE-7 Cancelled EE-8 Circuit Breakers EE-9 Terminal Blocks, Fuse Holder, Lamp Holder, Relay Socket EE-10 Relays; Control, Time, Protective, Overload EE-ll Switchboard Wiring EE-12 Motor Control, Center Subassembly Items EE-13 Wire Lugs, Connectors EE-14 Limitorque Actuator Parts DM/49350 JCO 88-15, Fev. 1 Page 46 of 71
l-EE-1 OPERABILITY REVIEW' L TECHNICAL AND QUALITY EVALUATION OF l COMMERCIAL GRADE ITEMS Item Description Contact Blocks,' Breaker Parts 1 Plant Functional Requirements These items are subcomponents used in control panels.
Provide continuity and maintain the structural integrity of the connection. Maintain insulation between terminal points.
The insulation resistance must be high enough to meet design requirements for circuit accuracy, if installed in and required for harsh environments.
Critical Characteristics Product identifier, configuration, voltage rating, current rating, materials, dielectric strength.
Evaluation /Ouality Verification
. Operability of the terminal blocks during normal operation or for mild environment EQ applications is established by successful operation and functional testing'of the circuit. Additional operability is demonstrated' during return to service functional testing in accordance with the applicable ' maintenance procedures (MP-1-4, NP-1-5, MP 6, and MP-1-7)
Environmental and seismic qualification: Environmental and seismic qualification of the parent component is maintained by ensuring that the replacement subcomponents are like-for-like. Critical characteristics for these parts are simple and specific. As such, like-for-like for
)
these items are established by visual inspection and installation checks. Like-for-like replacements are also ensured by Administrative ,
Order A0-T-25, " Procurement and Replacement of Environmentally Qualified '
' Electrical Equipment", put into effect prior to September 1986.
NC/49020 JC0 88-15, Rev. 1 Page 47 of 71 1
EE-2 OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF l- COMMERCIAL GRADE ITEMS
, i-l Item Description Heet shrink tube, wire insulation tube, electrical tape, cable splice kit
~
critical Characteristics I Product identifier, configuration, dimension, material composition, design rating, and performance.
Evaluation / Quality Verification Operability of the circuit during normal operation or for mild environ-ment EQ application is established by successfully following installation procedures. Operation and functional testing of the main component following installation per Installation Standard (IS) No. E-7, Rev. O, "Try-Testing Motors Transformers, and Miscellaneous Loads" further establishes operability.
Seismic qualification: These items are insensitive to seismic effects.
Environmental qualification: Environmental qualification of the parent component is maintained by ensuring that the insulating materials and configuration have been qualified for the intended use. Critical charac-teristics for these items are simple and specific. It is unlikely that design or construction would change between production runs for these types of items such that performance characteristics would be affected.
Administrative Order A0-T-25, " Procurement and Replacement of Environ-mentally Qualified Electrical Equipment", put into effect prior to September 1986 ensures'that applicable materials are used.
Installation Standard No. E-10 covers the termination, splicing, and ,
Jacket repair of electrical cables and wires with Raychem materials, l especially those requiring environmental qualification.
Maintenance Request (MR) No. 87-1758, which responded to NRC Information Notice B6-53, provided an assurance that all EQ Raychem heat shrinkable tubing splices have been inspected and all rework performed, and all necessary QC inspection was undertaken to ensure the conformance of the work. EQ Documents Record No. 9 for Raychem splice and Record 86 for Raychem nonstandard terminations exist to further validate the qualifi-cation of Raychem splices and their accessories.
NC/49020 JCO 88-15, Rev. 1 Page 48 of 71
i EE-4 OPERABILITY REVIEW
-]
TECHNICAL AND QUALITY EVALUATION OF j COMMERCIAL CRADE ITEMS
~
Item Description Fuses,. overload heater' elements.
Plant Functional Requirements.
' Circuit overcurrent/short circuit protection with specific time / current interrupting characteristics.
Used also for. circuit isolation and coordination.
Items are installed in both environmentally and seismically qualified devices and must not invalidate existing qualification.
Critical characteristics Product identifier, current rating, interrupt rating, time / current res-ponse, dimensions, performance.
Evaluation /Ouality Verification
. Nuclear Plant Engineering Electrical Branch has established Design' Standard 3.2, " Criteria for New/ Replacement Fuse Selection, Fuse Numbering,-and Fuse Tag Color Coding", to provide criteria for the selection of pre-evaluated fuses for plant applications. This guidelines provides assurance that correctly sized and selected fuses are utilized at Trojan. Fuses for .lE use must be previously evaluated or qualified.
To' provide assurance that commercial-grade fuses for use in IE applica-tions at Trojan have been supplied in accordance with the specifications and dedicated, the following inspections are performed at receipt:
Resistance Measurement Visual Inspection Dimensional Inspection Seismic qualification: These items are seismically rugged because they are small, structurally simple, and do not have moving or fragile parts.
NC/49020 JCO 88-15, Rev. 1 Page 49 of 71
EE-5 OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS Item Description Electronic subassembly items (resistors, printed circuit boards, diodes, transistors, thyristors, capacitors, integrated circuits, modules, transducers, amplifiers)
Plant Functional Requirements With the exception of printed circuit boards, these are commodity-type items used in various instrument and control equipment. Though the functional requirements of each item are specific, they are used in a diversity of assembly needs such as voltage / current limiters, signal blocking, filtering, and other specific functions. Items are installed in both environmentally and seismically qualified components and must not invalidate existing qualifications.
Critical Characteristics Product identifier, configuration, d{mensions, electrical values (resistance, capacitance, etc) wattage rating, voltage rating, and tolerance (circuit boards may have specific logic and output requirements).
Evaluation /Ouality Verification Operability of these subcomponents during normal operation or for mild environment EQ applications is established by successful operation and functional testing of the parent component.
Seismic qualification: These items are seismically insensitive because thsy are small, structurally simple, and do not have moving or fragile parts.
Environmental qualification: Environmental qualification of the perent component is maintained by ensuring that the replacement subcomponents are like for like. Critical characteristics for items of this type are very simple, specific and based generally on function. Like-for-like can be established for these items by correctly identifying the product identifier, visual inspection at time of installation, and post-installa-tion operative testing. The selection of like-for-like replacements is also ensured by Administrative Order A0-T-25, " Procurement and Replace- i I
ment of Environmentally Qualified Electrical Equipment", put into effect prior to September 1986.
NC/49020 JC0 88-15. Rev. 1 >
Page 50 of 71 L_________._.______
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gg-6 is OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS
.. . Iten Description
-Limit switch, micro switch, selector switch, push button-
. Plant Functional Requirements
~
Limit and' micro switches are used for position indication and equipment
- interlocks.
Selector switches and push buttons are used for equipment control.
Critical Characteristics Product identifier, configuration, contact rating (voltage, continuous current, and interrupting capacity), contact arrangement.
Evaluation / Quality Verification Operability-of limit switches, micro switches, uclector switches, and
. push buttons during normal plant operation and for the mild environment application is established by successful operation and return to service functional testing after repairs in accordance with the applicable maintenance procedure (MP series) or af ter circuit modifications in accordance with Installation Standard (IS) No. E-7, Rev. O, "Try-Testing of Motors, Transformers, Heaters, and Miscellaneous Loads".
Seismic Qualification: Selector switches and push button switches by design are mechanically rugged and relatively insensitive to vibration.
Limit..and micro switches have been shown to be potentially subject to ,
spurious activation from seismic stresses. As such, seismic adequacy of replacement limit and micro switches used in safety-related applications '
.can.be established by.using like-for-like items or determining that no safety. impact would result from a spurious actuation.
Equipatent Qualification: Environmental qualification of the parent component is maintained by ensuring that the replacement subcomponents degradeable materials are like-for-like. The selection of like-for-like l replacements is ensured by Administrative order A0-T-25 " Procurement and Replacement.of Environmentally Qualified Electrical Equipment", put into effect prior to September 1986.
NC/49020 JC0 88-15, Rev. 1 Page 51 of 71
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l EE-8 OPERABILITY REVIEW 7
TECHNICAL ~AND QUALITY EVALUATION-OF 7
__ COMMERCIAL GRADE ITEMS
i
- i Item Description '
circuit breaker Plant Functional Requirements Provido power continuity and interrupt current flow with specific time /-
current characteristic responses.
Breakers should be selected to provide proper isolation and coordination with the other upstream and downstream breakers and fuses.
Critical Characteristics Product identifier, number of poles, voltage rating, current rating, interrupt rating, time / current response, dimensions, configuration, and performance.
Evaluation /Ouality Verification L
Operability of circuit breakers during normal operation or for mild environment EQ application is established by successful operation'and functional testing in accordance with the appropriate maintenance procedure (MP-1 series) or after modifications in accordance with Installation Standard No. E-7, "Try-Testing of Motors, Transformers, Heaters, and Miscellaneous Loads", Rev. O, February 16, 1983. The proper I operation of breakers is verified per these standards whenever installation replacement or testing of circuit components is performed.
Seismic Qualification: High voltage circuit breakers (4-kV and higher) are seismically rugged; however, circuit breakers (480-V and below) have demonstrated some performance sensitivity to seismic stresses. Determi-nation of acceptability for safety-related commercial-grade breakers must consider operating requirements under seismic conditions. Circuit breakers receive a seismic review based on similarity to a qualified unit, either through the Request for Design Change (RDC) process or Spare ~
Part Equivalency Evaluation Report or through a like-in-kind I replacement. An additional review of the qualification of circuit breakers is addressed in Attachment 2 of Table 12.
Environmental Qualification: There are no commercial-grade circuit breakers at Trojan requiring environmental qualification.
NC/49020 JC0 88-15 Rev. 1 Page 52 of 71 1
l-l EE-9 OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS l
- Item Description Terminal blocks, fuse holder, lamp holder, relay s'ckets o Plant Functional Requirements Used in control room and local control panels.
provide continuity and maintain the structural integrity of the connection. Maintain insulation'between terminal points.
The insulation resistance must be high enough to meet design requirements for circuit accuracy if installed in and required for harsh environments.
- Critical Characteristics Product identifier, configuration, material type, dimensions, voltage rating, current rating, and dielectric voltage withstand capability.
Evaluation /Ouality Verification Successful functional testing and operation of the circuit establish the operability of the item during normal operation or for mild environment.
Seismic Qualification: These items are seismically insensitive due to their rugged construction, configuration, and are passive during i operation.
Environmental Qualification: Environmental qualification of the parent component is nalntained by ensuring that the replacement subcomponents are like-for-like or are themselves environmentally qualified. Because of the simplistic characteristics asscciated with those types of items, a like-for-like determination of these items are typically established through visual inspection during installation. Like-for-like replacements have also been ensured by performing work in accordance with Administrative Order A0-T-25, " Procurement and Replacement of Environ-mentally Qualified Electrical Equipment", put into effect prior to September 1986.
NC/49020 JCO 88-15. Rev. 1 Page 53 of 71 j
-m__________.___._______.________.__.____.________.__.____ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ._____.__________________._j
I. ,
1I EE-10 ;
OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF 3 COMMERCIAL GRADE ITEMS Page 1 of 2 Item Description Relays (control, time delay, protective, overload) and contactors Plant Functional Requirements Control and time delay relays are used throughout the plant for equipment contcol and plant system functional logic.
Protective and overload relays are used to protect plant electrical egulpment to maximize system availability and personnel safety.
Contactors supply and interrupt power to the low voltage equipment in accordance with equipment control logic.
Relays and contactors are installed in both environmentally and/or seismically qualified equipment and must not invalidato existing qualification.
Critical characteristics Product identifier, voltage rating, contact configuration, contact current rating (continuous and interrupting), pull in voltage, dropout voltage, dielectric strength, insulation resistance, seismic resistance, configuration, materials and dimensions.
Evaluation /Ouality Verification Operability of relays and contactors during normal plant operation and the mild environment application is established by successful function during normal plant operation. Additional operability is demonstrated through return to service functional testing after repairs or modifica-tions in accordance with Installation Standard No. E-7, Rev. O, "Try-Testing of Motors, Transformers, Heaters, and Miscellaneous Loads", and j
following repairs in accordance with MP-1-17. " Time Delay Devices" or MP-2-14. " Protective Electric Relays".
Since relays and contactors have been shown to be sensitive to spurious activity and contact chatter as a result of seismically induced motion, seismic adequacy of replacement relays and contactors used in safety-related applications can be established by using items like-for-like to originally qualified relays, or determining that no safety impact would result from chatter or spurious actuation. Relays are considered qualified based on a seismic review conducted prior to installation. An additional review of this qualification is addressed in Attachment 2 of Table 12.
l JC0 88-15, Rev. 1 l Page 54 of 71
EE-10 OPERABILITY REVIEW TECHNICAL AND QUALITt EVALUATION OF COMMERCIAL GRADE ITEMS Page 2 of 2 Equipment Qualification: Environmental qualification of the parent i component is maintained by ensuring that the replacement subcomponents !
I are like for like. The selection of like-for-like replacements is ensured by Administrative Order A0-T-25. " Procurement and Replacement of Environmentally Qualified Electrical Equipment", put into offect prior to September 1986, 1
NC/49020 JC0 88-15, Rev. 1 Page 55 of 71
1 i
EE-11 j OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS i
Item Description Wires, including panel wiring Plant Functional Requirements To provide power or control signal to equipment / device and interconnect devices in panel / switchboard.
Critical Characteristics Product identifier, voltage rating, conductor size, ampacity, insulation resistance, conductor resistance.
Evaluation /Ouality Verification Wire is a highly standardized and widely used product. For normal plant operation and mild environment application the adequacy and operability is verified by selecting proper size, rating and insulating material for the application. Standard receipt inspection and proper installation by trained individuals serves to ensure the adequacy of the product.
For harsh environment applications, only an EQ qualified wire may be used. To evaluate the controls in place at Trojan, plant Maintenance was contacted. Maintenance has confirmed that all wiring changes in control i panels / switchboard have been done only as a result'of RDCs initiated by NPE. For these changes, NPE specified/ approved wire is used. No wiring changes have been made during routine maintenance. Therefore, it can be concluded that qualified cables / wires have been used for the safety-related applications in harsh environment. A sample review of five MRs l related to wiring changes in the plant indicated that only qualified wires / cables (GE vulkene supremo) have been used for safety-related equipment.
Seismic qualification is not applicable to wire.
i NC/49020 g JC0 88-15, Rev. 1 Page 56 of 71
i EE-12 OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS I
Item Description
)
Motor control Center Assembly Parts (non-structural).
'l Critical Characteristics product identifier, configuration, nominal materials, dimensions.
Evaluation /Ouality Verification All safety-related motor control centers are located in mild environ-ments. The operability of Motor Control Centers following repair is established by successful operation of the controlled equipment during normal plant operation, surveillance testing, and return to service functional testing in accordance with MP-1-7, "480-Volt Motor-Control Centers and Molded-Case Circuit Breakers", or in accordance with Installation Standard (IS) No. E-7, Rev. O, "Try-Testing of MotArs, Transformers, Heaters, and Miscellaneous Loads". This is assur 2 by selecting like-for-like replacement parts and ensuring proper installation.
Seismic Qualification: Seismic qualification of the parent component is maintained by ensuring that the replacement subcomponents are like for like. Critical characteristics for these items are simple and specific.
Like-for-like is typically established for MCC assembly parts by proper !'
selection, visual inspection, and proper fit during installation.
Environmental Qualification is not required.
l l
C/49020 JC0 88-15, Rev. 1 Page 57 of 71
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EE-13 OPERABILITY REVIEW TECHNICAL AND. QUALITY EVALUATION OF.
COMMERCIAL GRADE ITEMS Item Description Wire lugs, connectors Plant Functional Requirements Provide electrical continuity and maintain the integrity of wire terminations.
Critical Characteristics Product identifier, configuration, wire size, and voltage rating.
Evaluation / Quality Verification Installation Standard No. E-3 (Termination and splices) ensures the integrity of cable termination utilizing these parts. This procedure also.
emphasizes the use of solderless, noninsulated, ring-tongue' lugs /
connectors. The capability of these items to support the operability of the system during' normal operation or for EQ applications is established by successful operation and functional testing of the main component, since the critical characteristics are not significantly affected by harsh environments.
Seismic Qualification: These. items art seismically rugged, structurally strong, and do not have moving parts. Calibrated crimping tools are used on all safety-related wires connectors and lugs per Installation Stan-dard No. E-3 to ensure sound connections.
Environmental Qualification: Environmental qualification of the parent component requires no additional controls be placed on the noninsulated !
lugs and connectors.
NC/49020 l
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Page 58 of 71
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l J
EE-14 OPERABILITY REVIEW
' TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS U"
Item Description l
Limitorque actuator parts #
. Plant Functional Requirements Provide valve control, maintain electrical integrity.
Critical Characteristics Product identifier, dimensions, materials, voltage rating,' dielectric strength, and HP (motor).
Evaluation /Ouality 7 verification Limitorque actuator parts procured through February 1987 had Quality Level Code D1, which required the supplier to incorporate appropriate QA
. requirements'in subtier procurement documents. Af ter February 1987, ,
Limitorque parts procurement was removed from the Quality-Related Vendor
List. However, for safety-related Limitorque actuators, only previously procured as Quality Level D1 parts are used. I PGE has initiated and is currently involved in an extensive effort to dedicate Limitorque commercial-grade items. PGE is having the dedica- {
tions performed by a third party. All procedures, critical characteris- '
tics, acceptance methods and acceptance criteria are reviewed PGE dedi- i cation engineers. This process ensures that only controlled parts are l used for safety-related actuators, i
NC/49020 l
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JC0 88-15, Rev. 1 Page 59 of 71 m __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____ _ _____ _ _____ _ _______ _ _ :
l NOTE: This appendix contains the Mechanical Technical f
Evaluation used by the JCO Task Group Engineers '
for verifying the adequacy of installed items in their respective applications APPENDIX F Mechanical Technical Evaluations The Mechanical Material Types were separated into nine categories designated M1 through M9. These categories were established considering the common functional characteristics among the items. All mechanical items installed were evaluated and identified as belonging to one of the following nine categories:
Technical Evaluation Desir, nation Applicable Material Types M1 Incidental Items M2 Fasteners and Parts M3 Pipe, Pipe Support, Structural Steel M4 Materials Exempted by Section XI Subsection IWA 7400 MS Pre-engineered Catalog Items M6 Valves, Valve and Pump Structural Replacement Parts M7 Wedge Anchors M8 Simple Commodities M9 Quality-Related Items M10 Weld Consumables The evaluations performed to determine the acceptability of commercial-grade mechanical products for designations M2 through M8 are presented in this appendix.
DM/49360 JC0 88-15, Rev. 1 Page 60 of 71 l
.M-l' OPERABILITY REVIEW.
TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS
! Item Description Material types incidental to plant functional requirements. Operational and' maintenance support supplies; chemicals (nonboron), glass sheet, janitorial supplies, lapping compound, miscellaneous paint, sealoit, shim stock, and thread lubricant. Items required for normal plant operation:
chart paper, coatings (outside Containment), filters, gaskets, gauges,.
packing, pipe insulation, and strainers.
Plant Functional Requirements Operational and maintenance support. Miscellaneous non-safety-related functions; plant serviceability.
Critical Characteristics N/A.
Evaluation / Quality Verification These iticidental items are required only during norme3. systems operations.
They are incidental to plant functional requirements provided configuration controls during maintenance and design modifications apply. Simple checks.
at the receipt and installation or use of the commodity serve to assure adequacy of these items.
JC0 88-15, Rev. 1 Page 61 of 71
3 M-2 OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL CRADE ITEMS Item Description Fasteners and parts. t plant Functional Requirements Structural connections.
l Critical Characteristics Strength properties, chemical composition.
Evaluation /Ouality Verification In responding to the material adequacy issues identified in NRC Bulletin 87-02, Fastener Testing to Determine Conformance With Applicable Material' Specifications, and NCR 87-417, pGE performed'an extencive study of fasteners utilized by Trojan. The results of this study indicate that fasteners utilized in Trojan are adequate.
During the course of evaluating fastence proporties under NRC ,
Bulletin 87-02 and NCR 87-417, approximately 352 separate stocking '
categories of fasteners were examined. The fasteners tested were typically procured commercial. grade or under a system that was equivalent to commercial grade. Of the 352 categories, 175 were subjected to complete mechanical and chemical testing. This level of testing represents one sample per 133 individual pieces, which is far in excess of the usual production testing level of one sample of 800 individual pieces. At the end of this evaluation program, which encompassed nuts, bolts, and washers made of carbon steel, low alloy steel, and stainless steel, only one lot of approximately 32 stud bolts was found to be unsuitable for use "as-is".
This represents 0.14 percent of the items in stock. Of those fasteners specifically provided as part number, identified spares, or larger fasteners over 3/4 inches in diameter, none were found to be unsuitable for service. These results provide considerable confidence that fasteners utilized at Trojan are adequate.
To prevent future occurrences of fastener material problems, the following corrective actions have been taken by pCE:
- 1. Receipt inspection procedures have been revised to include inspection of critical fastener attributes.
- 2. plug and ring gauges have been procured and are in use to verify dimensions and thread fit. Hardness testing equipment has been purchased and will be used to verify hardness of fasteners on a ,
sampling basis. This will be implemented by March 1, 1989.
- 3. Vendors with a history of problems in compliance with purchase orders have been identified and downgraded to non-quality-related procurement.
DM/49360 JCO 88-15, Rev. 1 page 62 of 71
II l M-3 Page 1 of 2 i OPERABILITY REVIEW j TECHNICAL AND QUALITY EVALUATION OF l COMMERCIAL GRADE ITEMS j 1
1 t'
Item Description
(
Pipe, pipe' supports, structural steel.
Plant Functional Requirements Maintain pressure boundary integrity and structural integrity.
Critical Characteristics
- Strength properties, chemical composition, shapes and dimensions.
Evaluation / Quality Verification The shapes, dimensions, and absence of damages to these products have been verified at receipt of materials or by preservice inspections. In addi-tion, certificates of conformances or CMTRs have been provided by the suppliers for most of these products. These certificates attested to the material conformance with the required strength and chemical properties per ASTM standards.
1 NCR 88-295 and 88-600 identify a nonconforming condition of commercial-grade material application for ANSI B31.7 applications. As part of the effort to disposition this NCR, PGE undertook an extensive testing effort to verify the adequacy of pipe, pipe fittings, pipe support, and structural s' eel materials procured commercial grade. Samples from a total of over 100 different heat of materials were tested satisfactorily. Thece samples cover a wide range of pipe and fitting sizes and a wide range of structural steel shapes and sizes, as illustrated below:
- 1. Tube steel sizes from 2 x 2 x 1/4 to 6 x 6 x 1/2.
- 2. Plate sizes from 1/4 inch to 2-1/2 inches.
- 3. Angle sizes from 1-1/2 x 1-1/2 x 1/4 to 6 x 6 x 3/4.
- 4. Wide flange sizes from 4 x 13 to 8 x 31.
- 5. Channel sizes from 6 x 13 to 8 x 18.75.
- 6. Flat bar sizes from 1/8 inch to 1 inch.
- 7. Threaded rod sizes from 5/8 inch to 1-1/4 inches.
JC0 88-15, Rev. 1 Page 63 of 71 L
I M-3 page 2.of 2
- 8. Piping sizes from 1 inch Sch 80 to 14 ' inches Sch 60.
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'9. Pipe fittings tested include 90 degree elbow, 45 degree elbow, flanges, couplings.
' Laboratory tests were performed on material available in the warehouse and l
in.some cases scrapings from installed materials. Some of this material- -
was tested to provide a date base for Equotip' hardness testing of installed ,
material. Other material was tested to validate the.CNTRs for installed j material 1from the same heat. -The laboratory tests typically included I tensile, chemical, and Brinell hardness tests. Many of.the materials used to validate the CMTRs of installed material also had Equotip hardness tests l run prior to dispatch for laboratory testing.
l The structure of the selection process included accessibility. as a criteria where. nultiple items came from single material heats. This introduced an
. element of randomness into the tested sample group. This element of ran-domness combined with the acceptable test results to date provides confi-dence that the installed material is acceptable for service.
Homogeneity or consistency of materials has been addressed by sampling without bias and testing 21 heats of piping materials and comparing these test results with the manufacturers' CMTRs. The comparison has shown good agreement between the pairs of results for each heat. The magnitude of-differences in general has been small, approximately the magnitude expected of check analysis variation. The mechanical test results of 15 of these 21 heats were also consistent with the CMTRs. Six heats were not laboratory. tensile tested because samples were not available.
Additionally, 62 heats of various support materials have had laboratory chemical and tensile tests performed. These materials were all-found to comply with materials specification test requirements with a few minor exceptions. The minor exceptions were all evaluated and were determined to be acceptable.
All this data on samples selected without bias, 83 chemical and 77 nachanical tests, indicate that the materials are consistent and that homogeneity is not a problem.
The requirements for impact testing of carbon steel materials for the main feedw ter piping were also reviewed. One of the original specifications procurid certain feedwater pipe' sections with impact testing. One heat of-replact ment piping (approximately 6 feet in length) was ordered to the specification requiring impact testing. The CMTR for this pipe included impact test results. Impact testing has been performed to complete the verification of this CMTR.
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M-4 OPERABILITY REVIEW-
. TECHNICAL AND QUALITY EVALUATION'0F COMMERCIAL GRADE ITEMS Item Description Materials exempted by ASMC Section II Subsection IWA 7400; gaskets, 0-rings, packings,-seals.. ring (wear, snap, retaining, seal), 1-inch nominal pipe size and less, nonstructural valve and pump parts.
Plant Functional Requirements Miscellaneous items; equipment serviceability. Piping systems; design pressure.
Critical Characteristics Miscellaneous ltem; configuration. Pipe; size, product alloy designation.
Evaluation / Quality Verification Per ASME Section XI Subsection IWA-7400, certain nonstructural items and sma11' product items are exempted from the stringent Section XI inspection requirements. These itema include the following:
- 1. Caskets and seals.
- 2. . Nonstructural valve and pump internal parts.
- 3. One-inch nominal pipe size and less (piping, valves, fittings, tubing).
This Scction XI exemption implies that these items have simple critical I characteristics which are standard controls by the manufacturers for product performance. Simple checks at receipt and installation will assure the adequacy of these items. Additionally, piping systems are inservice inspected by pressure test / normal service conditions.
1 In addition to the above items specifically exempted by subsection IWA-7400, '
other commodities with simple characteristics are considered applicable to this category. Examples are as follows:
- 1. Pins,
- 2. Key stock.
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M-5 OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS Item Description Pre-engineered catalog items: Unistrut and fittings, beam clamps, swagelok fittings, conduit hanger and fittings, tubing clamps, grout, coating, U-bolts, snubber parts, turbino parts, rebar, brackets, engine parts,
. saddles.
Plant Functional Requirements l Structural loads.
Critical Characteristics Product identifier. Subassembly items; the assembly item designation.
Evaluation /Ouality verification i
These items are designed and manufactured to the manufacturer's product catalog specifications and periodically prototype-tested to maintain specific physical and performance characteristics. They are not subjected !
to any additional design code requirements. Their capacities and func-tional specifications are based entirely on the manufacturer's designs and prototype-test results.
In addition, most of these pre-engineered items have been extensively utilized in the industry and found to be effective. Based on theso opera-tions, the material adequacy of these products is considered adequate.
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M-6 OPERABILITY REVIEW.
TECHNICAL AND QUALITY EVALUATION OF
{ COMMERCIAL GRADE ITEMS I
7 C. Item Description-Small-bore' valves, non-ASME Class 1; structural valve and pump parts, bear--
'ings diaphragmst .
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' Plant Functional' Requiremerlts Pressure retaining or functional parts.
Critical Characteristics Valves; size. Pressure. rating.' Parts, bearings, diaphragms; performance. c Evaluation /Ouality Verification The conformance with the manufacturer catalog data or PGE specification required was verified in the delivery documents. The mandatory preservice-tests required by Section XI and performed by PGE verified.the products
. capabilities to perform the required functions-(opening / closing times,- :!
leakage)'under the operating conditio",s (pressure). -The Section XI inservice inspection tests and simple checks on the product i#cntifier for-these items are adequate to ensure their continued operability.
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OPERABILITY 'dEVIEW -
TECHNICAL AND QUALITY. EVALUATION OF COMMERCIAL GRADE ITEMS ,_
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Item Description Wedge anchors'.'
- , , ' Plant'FunEtional Requirements Provides structural connections and anchorages for pipe supports and s teel . st ructures .
Critical Characteristics Concrete strength, proper installation (torque setting).
' Evaluation /Ouality Verification-Wedge anchors are proof tested by installing torque procedures to a value in excess of allowable loads. Certificate of Conformances are supplied by approved suppliers. This verifles the required anchor bolt strength is obtained.
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., OPERABILITY REVIEW TECHNICAL AND QUALITY EVALUATION OF COMMERCIAL GRADE ITEMS V
-~ Item- Description Simple commodities: pins, keystock, machine screws and nuts.
Plant Functional Requirements
, Miscellaneous.
Critical Characteristics Physical dimensicas, chemical composition.
Evaluation /Ouality Verification These items have simple critical characteristics which are normally con-trolled by a broad multi-industry commodities market. Simple checks'at
. receipt and installation usually-serve to assure adequacy of these simple items.
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,. M . OPERABILITY REVIEW-~
TECHNICAL AND QUALITY EVALUATION OF' COMMERCIAL GRADE ITEMS l
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' Item Description Quality-related items '(non-safety related).
Plant Functional Requirements Miscellaneous non-safety-related functions.
Critical' Characteristics-NA.
Evaluation /Ouality Verification certain quality-related items do not perform any safety-related functions.
Such items are utilized in the following systems which are characterized as q'uality 'related only:
- 1. Control access barriers.
'2. Security.
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- 3. Radwaste.
4.- Fire protection.
- 5. Cranes and hoisting.
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OPERABILITY: REVIEW-l TECHNICAL ANDl QUALITY EVALUATION OF_ ,
-COMMERCIAL ~ GRADE ITEMS Item Description N
Weldins eonsumables.
L Plant Functional Requirements.
Pressure retaining or_ functional parts.
CriticaltCharacteristics Welds; integrity.:
! Evaluation / Quality-Verification The carbon steel welding activit'les conducted in 1986-88 that have been
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referenced to-date show that the coated electrode welding consumribles were manufactured by ASME Quality System certificate holders.. Material was.
ordered to.the applicable specification from ASME Section II Part C with material _ test reports. LThese_ certified material test reports.were verified by comparing. heat numbers'against the sealed cans of E7018 coated ~
electrodes during receipt inspection and found to represent the material in the sealed cans. The certified material test reports attested to the
- acceptabilityLof the material as well-as the material manufacturer's compliance'with NCA-3800 of Section III of the ASME B and PVC. There is no mechanism-by which the ' presence or absence of a quality assurance program on.the part of the material supplier could affect the. relationship between-the certified material test reports and the; welding electrodes in theirJ sealed and marked'enns. There is thus no concern for the acceptability of:
- this class of welding consummable.
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Welding filler ~m/terials (such as E703-2 and E70S-6) were also produced by manufacturers with ASME Quality System Certificates Who provided CMTRs.
These materials were ordered with CMTRs. One of the suppliers interviewed)
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l stated that the requirement' for CMTRs for a nuclear plant order would lead to the same identification and verification activities as if Section III of the ASME B and PV Code were invoked. Materials were drawn from stock of
' tested material and were' verified to match the CMTRs provided. PGE orders
'this filler metal so that identification is maintained on each piece of wire by heat' number.
All weld filler materials were produced by manufacturers having ASME-approved quality programs. All CMTRs had the manufacturers' Quality System
' Certificate number referenced or the program referenced with one exception.
One certificate did not list the quality program. Westinghouse, the supplier of the weld-rod, is in the process of providing a more complete CMTR for this heat.
Stainless steel welding materials for 1986-88 period follows the same systam as for carbon steel described above. A specific review of j L documentation during this time frame will be completed, j i
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