ML20235Z777
| ML20235Z777 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/03/1989 |
| From: | Barnes I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20235Z773 | List: |
| References | |
| 50-382-89-02, 50-382-89-2, IEB-88-001, IEB-88-003, IEB-88-010, IEB-88-1, IEB-88-10, IEB-88-3, IEIN-88-019, IEIN-88-027, IEIN-88-035, IEIN-88-046, IEIN-88-059, IEIN-88-19, IEIN-88-27, IEIN-88-35, IEIN-88-46, IEIN-88-59, NUDOCS 8903160232 | |
| Download: ML20235Z777 (19) | |
See also: IR 05000382/1989002
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-382/89-02
Operating License:
Docket: 50-382
Licensee: Louisiana Power & Light Company (LP&L)
317 Baronne Street
New Orleans, Louisiana 70160
Facility Name: Waterford Steam Electric Station, Unit 3 (W3SES)
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Inspection At: Taft, Louisiana
Inspection Conducted: January 9-13, 1989
Inspectors:
L. E. Ellershaw, Reactor Inspector
J. R. Boardman, Reactor Inspector
L. D. Gilbert, Reactor Inspector
W. M. McNeill, Reactor Inspector
Approved:
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I. Barnes, Chief. Materials and Quality
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Programs Section, Division of Reactor Safety
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Inspection Summary
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Inspection Conducted January 9-13, 1989 (Report 50-382/89-02)
Areas Inspected: Routine, announced inspection consisting of:
(1) followup of
previous inspection items; (2) followup)of HRC Information Notices and
Bulletins applicable to procurement; (3 inspection of 10 CFR Part 23
activities; (4) inspection of the procurement program including commercial
grade procurement; and (5) inspection of receipt, storage, and handling of
equipment and materials.
Results: Within the five areas inspected, three violations were identified.
During followup of previous inspection findings, two apparent violations were
identified. The first violation has been identified as one example of a three-
part violation (382/8902-03) dealing with the failure to follow procedures.
The specifics of this part pertained to the failure of LP&L to address
shelf-life requirements on a purchase order (P0) for repair kits
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containing Buna-N items, and is addressed in paragraph 2.a.
The second
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violation (382/8902-02) is identified in paragraph 2.c and addresses LP&L's
failure to impose 10 CFR Part 21 on P0s placed with Okonite Company for basic
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components.
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During followup of NRC Information Notices and Bulletins pertaining to
procurement problems, the NRC inspector determined that LP&L has satisfactorily
reviewed the information and taken appropriate actions.
During inspection in the area of vendor 10 CFR Part 21 reports, the NRC
inspector noted that LP&L appropriately reviews the reperts and evaluates
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possible deviations. A potential problem was identified however, with respect
to the clarity of instructions contained in Procedure UNT-6-015. The
instructions address the logging in of 10 CFR Part 21 reports to allow for
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tracking.
It was noted that even though reviews were in process with respect
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to three 10 CFR Part 21 reports, they had not been logged in.
It was suggested
that LP&L clarify the instructions to preclude the possibility of not
performing an evaluation as a result of the failure to log in a 10 CFR Part 21
report.
The largest part of this inspection effort was devoted to the procurement
program and its implementation.
It was in this area (paragraph 5) that the
second and third examples of Violation 382/8902-03 were identified. The second
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example dealt with LP&L not having documentation to show that commercial grade
resistors had been dedicated for use in a safety-related component. The third
example of the violation dealt with LP&L's failure to follow Procedure UNT-7-021
with respect to updating vendor manuals.
Five vendor manuals had not been
updated to include the correct vendor maintenance information pertaining to
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time-delay relays.
Thethirdviolation(382/8902-01) was identified (paragraph 5) during
inspection of the procurement area; however, it was not related to procurement
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activities. During review of the drawing and a work authorization for
Valve 2SL-V2505, a pressurizer surge line sample isolation valve, it was
identified that an SA-193, Grade 88, stud had been installed in the valve rather
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than the SA-193, Grade B6 or B7, stud required by the drawing.
The NRC inspectors also expressed concern regarding LP&L's not having a program
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to ensure that the installed life of parts does not exceed their qualified
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life.
It was also noted that LP&L did not appear to have procedures which
would prevent the use of commercial grade dedicated parts in safety-related
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applications different from that which the parts had been dedicated.
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addition, procedures were not identified which would provide significant
attributes for determination of "like-for-like parts when this was the basis
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for dedication of commercial grade replacement parts.
An urresolved item (paragraph 5) was identified which relates to the basis for
qualification of a material supplier who was providing fasteners.
The area of receiving inspection was reviewed during this inspection only in
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terms of the program content.
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DETAILS
1.
Persons Contacted
LP&L Personnel
- R. P. Barkhurst, Vice President, Nuclear Operations
- S. A. Alleman, Nuclear Quality Assurance (QA) Manager
- D. E. Baker, Manager, Nucleae Operations Support and Assessments
- V. M. Burgard, Procurement Engineer
- N. S. Carns, Plant Manager, Nuclear
- G. M. Davis, Manager, Events Analysis Reporting & Responses
- W. E. Day, Trending, Compliance, and Response Supervisor
- D. V. Gallodoro, Procurement Engineering Supervisor
- J. E. Howard, Manager, Procurement / Programs Engineering
- L. W. Laughlin, Site Licensing Supervisor
- J. R. McGaha, Manager, Nuclear Operations Engineering
- M. J. Meisner, Licensing Manager
- W. M. Morgan, Supplier Audit Supervisor
- D. F. Parker, Assistant Plant Manager,, Operations and Maintenance
- P. V. Frasankvmar, Assistant Plant Manager, Technical Support
- J. J. Zabritski, Operations OA Manager
J. J. Casso System Engineer
B. Collyer, Fire Protection Engineer
S. E. Farkas, Licensing Engineer
E. Fields. Electrical Design Engineer
C. R. Gaines, Events Analysis Supervisor
T. J. Gaudet, Licensing Engineer
D. Gilley, Maintenance Engineer
D. D. Grubic, Licensing Engineer
R. B. Hereford, Systems Engineer
J. Jackson, Nuclear Operations Support & Assessments Engineer
R. A. Legere, System Engineer
C. S. Matharu, Electrical Engineering Supervisor
B. G. Morrison, Licensing Engineer
B. J. Porter, System Engineer
R. D. Riser, Procurement Engineer
J. H. Roberts, Procurement Support Supervisor
G. C. Scott, Licensing Engineer
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B. J. Ward, Receiving Inspector
G. M. Wilkinson, Trending Complience & Response Engineer
G. C. Woods, Purchasing Supervisor
NRC Personnel
- T. R. Staker, Resident Inspector
- Denotes those attending the exit meeting.
In addition, the NRC inspectors
contacted other members of the licensee's staff,
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2.
Followup on Previous Inspection Findings
(92701,92702)
a.
(0 pen) Open Item (382/8417-01): The subject open item dealt with a
licensee identified problem. The problem dealt with certain ASCO
solenoid valves which had been purchased for W3SES having 125 volt
direct current (125VDC) coils which were not designed for a battery
system operating voltage of 110-136.2 VDC. At the time of the
initial inspection, the licensee was unable to provide a component
data base documenting that all safety-related valve applications had
been reviewed.
During this inspection, the NRC inspector reviewed the ASCO solenoid
valves installed in the emergency diesel generators (EDGs).
Licensee
documentation (Memorandum W3E83-0064) dated March 9, 1983, and ASCO
Directive VC-11 dated August 10,1981) indicated that these valves
required the use of type "HC" coils. Licensee review, however,
identified that the installed valves had type "HT" coils.
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telephone conversation with an ASCO applications engineer, the NRC
inspector confirmed that ASCO considered an "HC" coil as being
required for this application (based on design characteristics). The
NRC inspector notified the licensee of this finding, and requested
the licensee to evaluate this concern. The licensee confirmed to the
NRC inspector after contacting the EDG manufacturer who supplied and
certified the installed ASCO solenoid valves, that the use of an "HT"
coil was an apparent misapplication and a Justification for Continued
Operation (JCO) was written.
Subsequent to this inspection, on January 18, 1989, the licensee
identified to the Region IV staff in a telephone conversation that
the EDG manufacturer had provided additional documentation regarding
the acceptability of the installed valves and the onsite replacement
valves. The EDG manufacturer stated that acceptability was based on
testing for which it had documentation.
The NRC senior resident inspector is currently reviewing other
safety-related ASCO valve applications. Therefore, this item will
remain open pending completion of this review.
During the review of this open item, the NRC inspector also reviewed
the licensee's procurement of repair kits for the subject ASCO
solenoid valves on PO WP016013. The kits contain Buna-N items which
require shelf-life control, as stated in Procedure N0EI-152
Revision 1.
However, the P0 did not identify the-need for rbelf-life
control.
Failure to adhere to the requirements of Procedure N0EI-152
is contrary to the requirements of Criterion V of Appendix B to
10 CFR Part 50 and is considered to be an apparent violation
(382/8902-03). The licensee issued Quality Notice (ON) No. QA-89-009
on January 13, 1989, to accomplish necessary corrective action to
deal with this apparent violation.
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b.
(0 pen) Open Item (382/8810-02): This open item dealt with the
concern that the licensee had no program:
To identify required greases for the replacement of double
sealed or shielded safety-related antifriction bearings.
To prevent the installation of bearings received from a supplier
with an improper grease.
At the time of this inspection, the licensee had developed what
appeared to be an acceptable program to correct this concern;
however, the program has not yet been implemented.
The licensee provided an anticipated implementation date of March 1,
1989. Therefore, this item shall remain open pending subsequent
verification of program implementation.
c.
(Closed) Unresolved Item (382/8823-02): This item required further
review of LP&L's procurement practice for Okonite tape and cement
because of a question regarding whether or not the Okonite materials
were considered to be basic components, and whether the new LP&L
procurement practices complied with 10 CFR Part 21.
The NRC inspector noted that since mid-1985, six P0s had been issued
which did not impose 10 CFR Part P1, but identified an Okonite
equipment qualification (EQ) report as being applicable. The P0s are
14107, 12403, 10450, 97037, 85303, and 65603. During 1988, two P0s
were issued which reflected the new procurement practice of referring
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to the batch numbers used for EQ, again without imposing 10 CFR Part 21. The batch numbers were identified as 017172 and 016360.
The vendor controls placed on Okonite by LP&L consisted of qualifying
the vendor by surveillance, audits, and the performance of final
inspection at the vendor's facility by LP&L. The NRC inspector noted
that Okonite had been audited in July 1986, and the recent purchase
orders had waived the requirement for final inspection.
The NRC inspector additionally nnted that the P0s did not require
notifications be made to LP&L if Okonite were to subsequently find
that the supplied materials were defective. The same holds true with
respect to EQ reports.
In fact, suspect EQ reports have been the
subject of a recent W3SES LER (88-27). This failure to impose 10 CFR Part 21 on P0s for components subject to specification requirements
that are unique to nuclear facilities is an apparent violation of
Section 21.31 of 10 CFR Part 21 (382/8902-02).
It should be noted that in at least one case, occurring during
November 1988, Okonite did recall 45 cans of cement even though
10 CFR Part 21 had not been imposed on the P0.
d.
(0 pen) Violation (382/8823-01):
Failure to process vendor
information properly. This violation identified that service
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bulletins and similar information from vendors was not subjected to
the controls and reviewn required by internal procedures.
As identified in NRC Inspection Report 50-382/88-23, the remaining
corrective action to be verified in regard to this violation was the
" Key Vendor Contact Program." The NRC inspector found that this
program is in a draft status. The projected date for final
procedures is July 1989. Under the draft program, 41 vendors have
been identified and letters sent to all requesting. design history and
service bulletin history. To date, only two vendors have responded;
however, the information provided does not appear to be responsive to
all the questions asked. The vendors had not supplied information in
regard to such things as service bulletins. This violation will
remain open until the program is fully implemented and assessed,
e.
(0 pen) Violation (382/8823-03):
Failure to control the process of
dedication. This violation identified several examples of improper
dedication of commercial grade items for safety-related applications.
The NRC inspector verified the licensee's review of the dedication
efforts of the engineer who was responsible for two of the examples
cited.
It appears that his work has been reviewed and no further
examples were identified. As preventive actions, the licensee has
identified that they are working with Nuclear Management and
Resources Council (NUMARC). The NRC inspector found that this
activity has not yet resulted in any changes to current procedures,
or the establishment of new procedures which might provide greater
control of the dedication process. This item will remain open until
implementation of changes that will assure control of the dedication
process.
f.
(Closed) Violation (382/8823-05): Failure to justify the
acceptability of nonconforming circuit breakers for continued use.
This violation identified that although it was known by the licensee
that certain circuit breakers were nonconforming, a JC0 had not been
initiated.
The NRC inspector found that a JC0 was issued on September 20, 1988.
A review of the JC0 found it to be responsive to the identified
condition. The licensee also revised Procedure PLG-9-007 and
established a new procedure (N0P-019) which now requires
nonconforming condition identifications to be reviewed in light of
operability questions and to be assigned a high priority for
resolution of safety-related nonconformances. nese actions appear
to be appropriate; therefore, this violation is closed.
g.
(Closed) Violation (382/8823-06):
Failure to correct identified
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misclassification of equipment. This violation identified that some
commercial grade spare parts were identified in a 1983 audit to be
improperly classified as safety-related commercial grade items
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(Quality Class'III), but had not been subsequently downgraded to the
proper nonsafety-related classification '(Quality. Class IV).
The NRC inspector, after review of the licensee's. response'and
discussion with the NRC inspectors who identified.the spare parts in.
question, concluded that the misidentification; appeared to have been
limited to only the computer information in the Materials Management
Infomation System (MMIS) and did not involve the actual hardware
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identification.
3.
Followup'on NRC Infomation' Notices and Bulletins
(92701)
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- The objective of this area of the inspection was to ensure that the
licensee followed up on concerns regarding procurement activities
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identified in NRC Information Notices and Bulletins. A sample consisting
of _ the following Information Notices and Bulletins was reviewed:
Information Notices - 88-19, 88-27, 88-35, 88-46, and 88-59
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Bulletins - 88-01, 88-03, and 88-10
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a.
NRC Infomation Notice No. 88-19: Questionable Certification of
Class 1E Components.
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This notice identified that certifications provided by a vendor,
Planned Maintenance Systems-(PMS), might not be. valid.
The NRC. inspector found that the licensee had reviewed this notice
and documented their activity,in Memorandum W3P88-0099 dated June 13,
1988. The licensee'had reviewed their Qualified Suppliers
. List (QSL),the'purchasingdepartmentfiles,andtheirStation-
Information Management System (SIMS), in order to verify if. this
vendor had been procured from by LP&L for parts or services to be
used at'W35ES. The licensee found that PMS had not been used as a
vendor. .The NRC inspector also reviewed the.above items and
concurred with LP&L's conclusion.
In addition, LP&L placed a
" negative connitment" in the Commitment Management System. The
" negative connitment" would identify the problems cited in the
Information Notice if there was a. future attempt to use PMS as a
vendor . It would appear.that this would be an effective way to
preclude use of:this vendor.
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One observation 'noted by the NRC inspector is that the above
activities do'not address the possibility of PMS being used
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indirectly; i.e., as a subvendor. The licensee concurred that this
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aspect should be addressed in any future reviews.
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b.
NRC Information Notice No 88-27: Deficient Electrical Terminations
Identified in Safety-Related Components.
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This notice identified that electrical terminations in safety-related
components had deficiencies. The discussion identified the need to
review receipt inspection activities, among other inspections, to
preclude the cited problems.
The NRC inspector found that the subject of this notice was
identified in Problem Evaluation /Information Request (PEIR)
No. 20018, dated November 8, 1988. This document caused a review to
be performed of electrical terminations for the type deficiencies
identified; however, the review had not been completed at the time of
this inspection. As a result, the effectiveness of the LP&L review
and any impact on receipt inspection could not be determined at this
time.
c.
NRC Information Notice No. 88-35:
Inadequate Licensee Performance of
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Vendor Audits.
This notice identified that licensee audits at vendor facilities may
not reveal vendor failures to implement its QA program.
The NRC inspector found that the licensee had reviewed this notice
and documented its activity in a draft Memorandum W3P89-0008. A
review was performed of the QSL by the licensee and it was found that
three of the eight vendors identified in the notice had been used.
One vendor had been removed from the QSL for what appears to be the
same problems identified in the notice and at about the same time as
the notice was issued. Another vendor had been audited recently in
light of the same problems cited in the notice. The licensee was
satisfied that the identified problems were resolved and were not
germane to their procurement activities. The third vendor will be
audited within the next several months.
In addition, the licensee reviewed 'its vendor audit program, as
defined in implementing Procedures QAP-201, 207, 203, and 206. The
licensee concluded that its vendor audit program was satisfactory and
that continuing programs such as the Key Vendor Contact Program and
NUMARC programs should provide the necessary controls. The NRC
inspector reviewed the above and concurred with the conclusions,
d.
NRC Information Notice No. 88-46: Licensee Peport of Defective
Refurbished Circuit Breakers.
This notice was issued because refurbished circuit breakers may have
been supplied to licensees in a defective condition. The discussion
identified the need to review:
(1) the effectiveness of vendors in
terms of complying with the requirements of specifications and codes,
and (2) the licensee's verification of such requirements.
The NRC inspector found that the licensee had addressed this notice
in Memorandum W3A88-0130 dated December 2, 1988.
Company had, on November 17, 1988, identified, via a 10 CFR Part 21
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report, 35 suspect circuit breakers relatet to this notice. The
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licensee established that.the models in quostion were in a'
nonsafety-related application.and could ' account for all breakers
either installed or in. the warehouse. ' Althot.gh the breakers are
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nonsafety-related, LP&L is planning to remove and replace all suspect
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breakers.: The-NRC inspector reviewed the above records.and found
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that the SIMS did indeed identify the breakers as nonsafety-related.
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e.
NRC Information Notice No. 88-59:' Main Steam Isolation Valve Guide
Rail Feilure at Waterford Unit'3.<
This notice. identified that a failure had occurred at W3SES of
bolting in a main steam isolation valve (MSIV) supplied by WKM Valve
Division of ACF. Industries.
The discussion addressed nondestructive
examination.of all new bolts.
The licensee had addressed this notice in Memorandum W3P88-1204 dated
June 30,1988, and in an. independent engineering report dated
. June 20, 1988, both of which made the same recommendation with
respect to the nondestructive examination of new bolting. The NRC
inspector verified that LP&L had included the nondestructive
examination requirements in PO .17973, the procurement document for
new replacement bolts.
It would appear that implementation of the
corrective. actions identified in the notice were satisfactory.
f.
NRC 83u11etin No. 88-01: Defects in Westinghouse Circuit Breakers.
This bulletin identified safety concerns with Westinghouse'DS series
breakers. The discussion addressed remedial actions to correct
deficiencies, and' included replacement of the defective hardware.
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The licensee addressed this bulletin in Memorandum W3P88-0051 dated
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March 29, 1988, which showed that no Westinghouse DS series breakers
were in safety-related applications at.W3SES. A " negative
consnitment" was also entered into the Commitment Management System to
preclude future use of this type of breaker. The NRC inspector
reviewed the above and concurred with LPAL's conclusion. The
licensee's actions appear to be satisfactory.-
g.
NRC Bulletin No. 88-03:
Inadequate Latch Engagement in HFA Type
Latching Relays Manufactured by General Electric (GE) Company.
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This bulletin identified latching failures in HFA relays and the
acceptance criteria to be used for certain vintage relays.
The licensee addressed this bulletin in draft Memorandum W3P88-1274.
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To date, 27 relays have been inspected and found satisfactory.
Additional relays will be inspected during the 1989 outage under
Condition Identification No. ?$4790.
Rather than relying upon
receipt inspection to detect the latching failures, LPAL verifies the
adequacy upon installation. The NRC inspector found this activity,
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addressed in Procedures ME-7-036 and -037, included the acceptance
criteria addressed in the bulletin.
h.
NRC Bulletin.No.'88-10: Nonconforming Molded-Case Breakers.
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This bulletin is a followup to Notice 88-46 and requested that
licensees procure breakers from the manufacturer,.or others, in
compliance with applicable standards.
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The licensee, to date, is planning its a'pproach to this bulletin and
has not established any actions in the. procurement area.
Summary
The NRC inspector _ detemined that the licensee has satisfactorily-
followed up on procurement problems identified in NRC Information
Notices,and Bulletins.
No violations or deviations were ider.tified in this area of the
inspection.
4.
10 CFR Part 21 Inspection (36100)
The objective of this area of the inspection was to detemine whether the
licensee has established and implemented procedures and controls to ensure
the reporting of defects and noncompliance.
In this regard, the NRC
inspector. reviewed implementing Procedure UNT-6-015. " Identification,
Evaluation and Reporting of Defects and Noncompliance Under 10 CFR 21,"
Revision 1, dated September 23, 1988, and Change Request No. 1.
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Program
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The 10 CFR Part 21 program was previously. inspected and addressed in
- NRC Inspection Report 50-382/88-11. As noted in that report, the
program was being transferred from the Site Licensing group to the
Events Analysis Reporting and Response group. This inspection
focused on the transfer of the program responsibility and the
implementation of Procedure UNT-6-015 which replaced NSP-105. The
implementation was verified by review of vendor 10 CFR Part 21
reports which identified LP&L as being a recipient of possible
defective parts, and review of other reports, both internal and
external, which identified potential problems.
b.
Implementation in Regard to Vendor Part 21 Reports
In this area of inspection, the purpose was to determine whether
vendor 10 CFR Part 21 reports are reviewed and if the possible
deviations are evaluated.
In this regard, a sample comprised of the
following vendor 10 CFR Part 21 reports was reviewed:
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ITT Fluid Technology Corporation, Valve Division, dated
October 10, 1986
Tube Turns, Inc., dated February 16, 1987
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GA Technologies Inc., dated February 23 1987
Promatec, dated June 23, 1987
Arizona Nuclear Power Project, dated August 3, 1988
Anchor / Darling Valve Company, dated September 16, 1988
Limitorque Corporation (regarding melamine), dated November 3,
1988
Limitorque Corporation (regarding RH insulation), dated
November 3, 1988
(1)
ITT Fluid Technology Corporation, Valve Division (NRC No. 86-15
and LP&L No. L21-86-1).
This 10 CFR Part 21 report identified that air-motor operated
diaphragm valves could have natural frequencies of less than
33 Hertz. The licensee documented their review of this report
in Memorandum W3B87-0231 dated February 25, 1987, which
concluded that this problem did not' exist at W3SES based on site
specific information. This same conclusion was obtained by
Ebasco Services, Inc., who performed a similar study which is
documented in Report LW3-806-86, dated December 24, 1986. The
NRC inspector reviewed the above and found the handling of this
report to be satisfactory.
(2) Tube Turns, Inc. (NRC NO. 87-33 and LP&L No. L21-88-12).
This 10 CFR Part 21 report identified that certain penetration
assemblies had not been shop bydrostatically tested. The licensee
documented its review of this report in Memorandum W3P87-1006 dated
March 30, 1987, and concluded that the assemblies in question
had been field hydrostatically tested as part of startup testing
in lieu of shop testing. The NRC inspector reviewed the test
records applicable to the penetration assemblies and verified
that the assemblies had been field hydrostatically tested. The
NRC inspector concluded that the licensee's actions were
satisfactory.
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(3) GA Technologies Inc. (NRC No. 87-25 and LP&L No. L21-87-10).
This 10 CFR Part 21 report identified that RD-23 radiation
monitors supplied by GA Technologies, Inc. (GA) had Rockbestos
cable which, when at high temperature, could cause a loss of
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accuracy. The licensee addressed this 10 CFR Part 21 report in
Nuclear Operations Support & Assessments (NOSA) Report
No. 110-87 dated May 8, 1987, and PEIR 27503 dated December 28,
1987. The licensee concluded that the GA RD-23 radiation
monitors will maintain the required accuracy throughout tileir
designed range based on design calculations made with GA
guidelines and W3SES site specific information. The NRC
inspector reviewed the above reports and found them to be
satisfactory.
(4) Promatec Inc. (NRC No. 87-7).
This 10 CFR Part 21 report identified that silicone RTV foam
seals supplied by Promatec for use as fire barriers, may have
voids. The licensee addressed this problem in PEIR 88-128 dated
December 9, 1988, but not as a 10 CFR Part 21 report, because
Promatec, Inc., did not identify their communication as being a
10 CFR Part 21 report. The Promatec. Inc., June 23, 1987,
letter said the report was for information only. However, in
November 1988, while inspecting seals for different reasons, the
void problem was identified at W3SES and the licensee issued
Condition Identification No. 259458 dated November 25, 1988.
A
sample of 13 seals installed by Promatec, Inc. is planned to be
inspected.
It should also be noted that the NRC issued
issued Licensee Event Report (LER) gust 4, 1988, and the licensee
Information Notice No. 88-56 on Au No. 88-30, both of which
address this condition. The evaluation process is continuing
and the actions taken thus far appear to be appropriate.
(5) Arizona Nuclear Power Project (NRC No. 88-10).
This licensee issued 10 CFR Part 21 report that identified
numerous failures (approximately 76 in the past 2 years) of
Potter & Brumfield relays to rotate by spring tension upon being
deenergized by a safety system actuation signal. These relays
were supplied by Combustion Engineering, Inc. (CE), the nuclear
steam supply system manufacturer, for use in engineered safety
systems. LP&L had become aware of this problem as a result of
receiving Arizona's LER 88-074 dated August 9, 1988.
A " scratch
memorandum" dated August 18, 1988, identified that there were
only three failures fcund at W3SES during the same time frame.
LP&L is awaiting additional inforr
an from CE in regard to
this problem. The NRC inspector ieviewed the maintenance
history reports on these type relays and found the ir. formation
identified in the memorandum to be accurate.
(6) Anchor / Darling Valve Company (NRC No. 88-11)
This 10 CFR Part 21 report identified cracking of slides
furnished by Teladyne Republic to Anchor / Darling for actuators
of four-way valves that were used as main feedwater isolation
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valves. The licensee was aware of this problem because of an
August 16, 1988, letter from the vendor regarding the same
problem. This information had been entered into the N0SA system
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of vendor information. An informal review performed by LP&L
!
established that a different model number part had been supplied
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to W3SES. A phone contact by LP&L with the vendor established
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that the problem had not occurred with the model number supplied
to W3SES. Additional formal review of this problem is planned
by LP&L. The conclusions established to date appear to be
appropriate.
(7) Limitorque Corporation (re0arding Melamine) (NRC No. 88-19).
This 10 CFR Part 21 report identified breakage and post mold
shrinkage of melamine torque switches in motor operated valve
actuators. LP&L was recently made aware of this problem as a
result of LER-88-71 issued by Washington Public Power Supply
System (WPPSS) on December 7, 1988. Additional information was
also received in a memorandum dated November 30, 1988, from the
Nuclear Utility Group on Eouipment Qualification, as a result of
LP&Ls participation in that group. LP&L had previously been
made aware of this condition in NRC Information Notice NO. 86-71
and had performed and documented a review in Memorandum W3M86-0153
dated October 9, 1986.
Procedure HE-7-088 had been changed to
address inspection of the torque switches for this failure
mechanism. The NRC inspector verified the above information.
However, as a result of the recent WPPSS LER, additional review
of this problem is being planned by LP&L. The actions taken
thus fer appear to be appropriate.
(8) Limitorque Corporation (regarding RH Insulation) (NRC No.
88-18).
This 10 CFR Part 21 report identified that RH insulated motors
of motor operated valve (MOV) actuators may not develop full
rated starting torque at elevated ambient temperatures. The
licensee was aware of the information contained in this
10 CFR Part 21 report because of their participation in the
Nuclear Utility Group noted above. An informal review has
identified two MOVs located in high temperatures but less than
the delineated temperatures in the 10 CFR Part 21 report.
In
addition, the rated starting torque is less than the torque
stated in the 10 CFR Part 21 report. The informal conclusions
appear to be appropriate, and additional formal review of this
problem is planned by LP&L.
In addition to the above sample, an examination was made of completed
licensee reviews of 22 vendor 10 CFR Part 21 reports (LP&L Nos. L21-85-6,
L21-85-7, L21-85-8, L21-86-7, L21-87-1, L21-87-2, L21-87-4, L21-87-6,
L21-87-7, L21-87-12, L21-87-16 through L21-87-20, L21-87-22 through
L21-87-25, L21-87-27, L21-88-2, and L21-88-4.
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The NRC inspector concluded that appropriate reviews and' evaluations had
been performed on these reports.--
Summary
s
The NRC inspector found-that the vendor 10 CFR Part 21 reports are being
appropriately reviewed and the+ possible. deviations are being and have
been evaluated by the licensee.
It was noted by the,NRC inspector that
the three 10 CFR Part 21 reports received from Limitorque and-
Anchor / Darling had not been logged. in as required by the program defined
in Procedure.UNT-6-015, although reviews were.in progress.
To preclude the possibility of not perfoming'a required evaluation as a
result of not logging-a.10 CFR Part 21 report, the licensee should review'
and clarify the logging requirements addressed in Procedure UNT-6-015.
This is an inspector followup item (382/8902-04).
5.
Procurement Program (38701,38703)
The NRC inspectors reviewed the following documents to verify that
administrative. controls exist and that they provide measures to ensure
that-necessary technical and quality requirements are included in
procurement documents for safety-related items or services. The documents
were'also reviewed to verify that controls exist for the selection.
app'roval, and use of vendors. These documents were further reviewed to
ensure that responsibilities for implementing the established measures
were delineated in writing.
Document No.
Revision
Title
1
Safety-Related Procurement Methods &
Standards Technical & QA Statements
NOP-006
1.0
Nuclear Operations Procurement
QAP-200
3.
Scheduling of Supplier Quality Assurance
Section Audits
QAP-201
7
Supplier Quality Assurance Audit
QAP-202
5
Evaluation of Supplier's Quality
Assurance Program
QAP-203
2
Qualified Suppliers List
QAP-205
3
Supplier Surveillance
UNT-7-021
6
Spare Parts Equivalency Evaluation
Report / Parts Quality Level Determination
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The'NRC inspectors performed this part of the inspection using the
following methodology:
LThe licensee provided a listing, by' component identification number,
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of all safety-related components on which maintenance had been
performed during the last 2 years and which identified the.
maintenance work control documents involved; e.g., work
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authorizations (WAs).
,
The NRC. inspectors selected a sample of what a)peared'to be
safety-significant maintenance activities whic1 replaced component
parts.
The licensee provided. data showing warehouse. issues against the-
maintenance WAs selected by the NRC inspectors.
The licensee' identified the P0s for the warehouse issues identified
above.
The NRC inspectors reviewed a~ sample ~ of the P0s and WAs based on the
apparent safety significance of the replacement' parts purchased, and
other' factors.
Because of_the time required for this process, only
1
14 P0s and associated WAs'were reviewed. :In addition, many parts
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were not safety-related or even safety significant.. In some cases,
the lack of significance of the replacement part could not be
ascertained until the PO review was begun. When the lack of
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significance was identified, the P0 review was ended.
The following list consists of the WAs and POS reviewed in. order to
establish whether or not the installed replacement parts were of the
proper classification and if they had been properly purchased:
Work
Purchase
Authorizations
Orders
Component
System *
01008888
Studs
PSL
01021398
Valves
CVC
01016169
Valves
01003700
W-13957
Couplers
01003940
01016793
TR-5950
Jackscrew Adapter
01003379
TR-4718
Valve
MS
01020653
W-17820
Pump
01012916
Nuts
CVC
01008652
W-18139
Valve Stem
MS
01008652
W-18371
Nuts and Studs
MS
01009315
Valve Stem
01000663
W-13268
Nuts and Studs
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01017698
W-11794
Resistors
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- List of system' abbreviations
. CAP - Containment Atmospheric Purge
CVC - Chemical and Volume Control
FP - Fire Protection
MS - Main Steam
<
PSL - Primary Sampling
SI - Safety Injection
']
Of the 14 P0s reviewed in detail, one indicated a problem with the
. acceptability of replacement parts being ordered. The parts are
safety-related resistors, Stock Number 101-F65399, ordered on
]
00 W-11794-K, two of which were installed as shown on WA 01017698.
The part description is " resistor 10K ohm 55 watt FRWA22 TRW-8225." The
licensee did not have a complete connercial description of this resistor
(such as percent tolerance), nor documentation that the' commercial
resistor had been dedicated.for use in a safety-related basic component.
On January 13, 1989, the licensee issued QN-89-004 to resolve this
apparent violation of licensee Procedure UNT-8-001, Revision 12,
Section 5.2.1.4.
Failure to adhere to the requirements of'
' Procedure UNT-8-001 is contrary to the requirements of Criterion V of
violation noted in paragraph 2.a above-(382/8902-03)ple of the apparent
Appendix B to 10 CFR Part 50. -This is a second exam
.
In another case, it was noted on P0 L-01478, that item 166 was for 24
each, stainless steel 3/8" x 6" studs.
Immediately following this item
was a note that specified the material, specification to be ASME SA-193
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Grade B8 for all austenitic stainless steel bolts'and. studs. A review of
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the vendor's certificate of conformance (C of C) and LP&Ls Material
Receipt Inspection Report (MRIR) No. 666-82 showed that the 24-3/8" x 6"
studs were ASME SA-193, Grade B8, material.
Review of the applicable-
WA (01008888) and the Requisition on Stores ticket'showed that one SA 193
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Grade B8 stud was issued and installed on- April 13,1988, as a replacement
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for a damaged stud on Valve 2SL-V2505, a pressurizer surge line sample
isolation valve. Review of the Bill of Material on Drawing No. 1564-1539,
the valve design drawing, showed the required stud material to be SA-193,
either Grade B6 or B7, both of which are low alloy steels.
It would
appear that improper stud material was installed.
Failure to adhere to
documented drawings is contrary to the requirements of Criterion V of
Appendix B of 10 CFR Part 50 and is considered to be an apparent violation
(382/8902-01).
Subsequent to the inspection, further review of P0 L-01478 dated August 10,
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1981, which was placed with Hardware Specialty Company (HSC) Inc.,
revealed that there were 166 line items consisting of varied quantities
and sizes of fasteners; i.e., bolts, studs, and nuts. The P0 delineated
the specific ASME Section II ma'terial specifications that the ferritic
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steel and austenitic stainless steel fasteners were to be
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manufactured from.
It also required that for materials 1 inch or less
nominal diameter, a C of C to the material specification be provided.
For
materials greater than 1-inch nominal diameter, a C of C and a Certified
Material Test Report (CMTR) were to be provided showing the data required
by the applicable material specification and the appropriate paragraphs of
Section III, Subsection NC of the 1977 edition, 1979 Summer addenda of the
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ASME Code.
The NRC inspector had requested LP&L to provide copies of the
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documented basis for placing HSC on their Qualified Suppliers List (QSL).
The provided documentation consisted of two Ebasco Services Incorporated
vendor audits of HSC, and correspondence pertaining to HSC and the QSL.
The Ebasco audits dated April 23, 1981, and May 4. 1982, showed the
classification of HSC as being a distributor and a material supplier,
respectively. As a distributor or material supplier of ASME Code
material, the ASME Code requires that the material supplier be responsible
for surveying, qualifying, and auditing the quality system program of the
material manufacturers and suppliers of subcontracted services. Neither
of the Ebasco audit reports addressed this subject; thus, there was no
evidence to assure that this ASME Code requirement had been verified or
was being complied with. Comments by the Ebasco auditor in the " comments"
section of the May 4, 1982, report, indicate that HSC purchased items to
ASTM material specifications and subsequently supplied and represented
those items as complying with Section III of the ASME Code. The NRC
inspector did observe several HSC C of Cs and CMTRs for items purchased by
LP&L on P0 L-01478. Those documents attested to the items being in
compliance with Sections II and III of the ASME Code.
The available documentation did not provide adequate information to allow
the NRC inspector to concur with the statements contained in the C of C or
CMTRs. Therefore, this item is considered to be unresolved pending
inspection of HSC procurement activities by the Vendor Inspection Branch.
(382/8902-05)
During the review of the licensee's procurement program, the NRC inspector
reviewed selected vendor manuals included in the licensee's library of
Vendor Technical Information (VTI).
As a result of NRC Inspection
Report 50-382/88-10, the licensee had replaced a number of Agastat series
7000 time-delay relays.
During this VTI review, the NRC inspector noted
that the information in the manuals contained obsolete and incorrect
data for the removed relays. The new relays were installed under the
licenses station modification SM1701.
Contrary to the licensee's
Procedurc UNT-7-021, Revision 1, Section 5.4.3.2, the following manuals
had not been updated as requireu to include the correct vender maintenance
and other information for the replacement Agastat Series E7000 relays:
Numbers 457002146, 457000238, 457000225, and 4570000005, Revision 1
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Number 457000291, Revision 0
Number 457000281 Revision 6
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Number 457001225, Revision 9
Number 457000212, Revision 3-
This apparent procedural violation resulted in the issuance of Quality.
Notice No. QA-89-005, dated January 13, 1989, for accomplishment of
required. corrective action. This is a third example of an, apparent
violation of Criterion V of Appendix B-to 10 CFR Part 50 noted above and
in paragraph 2.a (382/8902-03)..
During this inspection, the following apparent weaknesses in the
licensee's procurement program were identified for which the NRC
inspector's review was not completed. This review will be continued
during a subsequent inspection. .
.
Certain parts, such as elastomeric seals, have both a design life and
'
a shelf life requirement. The time that the part is stored by the
licensee prior to installation (shelf life) must be subtracted from
the qualified life to determine the allowable installed life. The
licensee did not identify the existence of controls to ensure that
the installed life of parts.did not exceed their qualified life.
For parts purchased as commercial grade for safety-related
applications, the licensee performed dedication for use of the
replacement part in a specific safety-related component. The
licensee then stocked that part apparently as a generically dedicated
safety-related part. As such, the part could be installed in a
safety-related component which had different design requirements, and
for which it had not been dedicated. The licensee did not identify
the existence of procedures which would ensure that dedicated
commercial grade parts could not be used in safety-related components
for which the parts had not been properly dedicated.
The licensee did not identify procedures which provided significant
attributes for determination of "like-for-like" parts when this was
the basis for dedication of commercial grade replacement parts for
use in safety-related components.
6.
Receipt, Storage, and Handling of Equipment and Materials Program (38702)
The NRC inspectors reviewed the following documents in order to verify
that administrative controls exist and that they provide measures to
ensure that received materials and equipment will be examined for
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conformance with requirements specified on the procurement document. The
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documents were reviewed to verify that acceptance criteria were clearly
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established; requirements for documenting the performance of receipt
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inspections were delineated; controls existed with respect to
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nonconforming items, storage, handling of safety-related items; and
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responsibilities were assigned in writing.
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Document No.
Revision
Title
QAP-250
7.0-
Material Receipt Inspection
1
Material Storage Inspection
The NRC inspectors briefly reviewed the receiving inspection documents
while reviewing the procurement documentation for.the items selected in
paragraph 5 above. The reviewed documentation consisted of vendor
supplied documents and'MRIRs which address shipping damage,
identification, documentation received, protective devices, cleanliness,
and dimensions. All of the documents identified the' specific items, the
PO number, the acceptability of the specified attribute,j the inspector,
and the date.on which the-inspector signed the checklict.
While the program for receiving inspection appears to be adequate in terms
of defining the objectives, the NRC inspectors did not have. adequate time
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to inspect the' implementation of the program. The NRC will review this
area during a subsequent inspection.
7.
Exit Interview (32703)
The NRC inspectors met with the personnel. identified in paragraph 1 on
January'13. 1989, to discuss the findings and conclusion reached during
the irespection. The licensee personnel acknowledged the findings.
No
information was presented to the NRC inspectors that was identified by the
licensee as proprietary,
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