ML20236B421
| ML20236B421 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/01/1989 |
| From: | Brach E, Mcintyre R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236B415 | List: |
| References | |
| 50-282-88-201, 50-306-88-201, NUDOCS 8903210072 | |
| Download: ML20236B421 (27) | |
See also: IR 05000282/1988201
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Enclosure 2
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INSPECTION REPORT
U.S. flVCLEAR REGULATORY COMMISSION )
0FFICE OF NUCLEAR REACTOR REGULATION l
DIVISION OF REACTOR INSPECTION AND SAFEGUARDS
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Report Nos.: 50-282/88-201; 50-306/88-201
Docket Nos.: 50-282; 50-306
Licensee: Northern States Power Company
414 Nicollet Hall i
Minneapolis, Minnesota 55401 j
Facility Name: Prairie Island Nuclear Generating Plant
Units 1 and 2
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Inspection At: Red Wing, Minnesota l
Inspection Conducted: October 24 through November 4, 1988
-Inspectors: b
Richard P. McIntyre, Team Leaderf ~
Ap . L7!64
Date'
VendorInspectionBranch(VIB)
a
R. L. Pettis, Reactor Engineer, VIB !
S. D. Alexander, Equipment Qualification
and Test Engineer,.VIB i
W. P. Haass, Senior Reactor Engineer, VIB !
Consultant: P. R. Farron, Nuclear Energy Consultants, Inc.
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a Approved By: // / Ak
E.' M llram Brach,J hief
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Fat'e
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Vendor Inspection Branch
Division of Reactor Inspection and
Safeguards
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8903210072 89031o
O ADOCK 05000282
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Inspection Summary
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Inspection from October 24 through November 4,1988 (Reports Hos. 50-282/88-201; ,
50-306/88-201) '
Areas Inspected: A special announced inspection was conducted by the
headquarters Vendor Inspection Branch to review the implementation of the
licensee's vendor interface program and the program for the procurement of
items for use in safety-related applications at the Prairie Island Nuclear
GeneratingPlant(PINGP). The inspection team reviewed the documentation of
specific vendor related technical issues including 10 CFR 21 notifications
received at PINGP and the documentation concerning the procurement of safety
significant items, including molded case circuit breakers.
Results:
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I. PROCUREMENT
The NRC inspection team reviewed the current programs for the procurement
of parts, components, and equipment to be used in safety-related applica-
tions at the PINGP. This review addressed the procedures that govern the
procurement process as well as the methods used to upgrade commercial
grade items (CGI's),for use in safety-related applications. A program
description and the results of a review of the PINGP procurement
procedures are contained in Appendix B to this report. To evaluate the
implementation of the program, the NRC inspectors reviewed selected PINGP
procurement of items to be used in safety-related systems, procured both
commercial grade and safety-related from approved suppliers having a
10 CFR Part 50, Appendix B, Quality Assurance (QA) Program.
A. Procurement Package Reviews-General Comments
To evaluate the procurement of replacement piece-parts, components,
and equipment for use in safety-related systems, the inspectors
reviewed a list of all procurement Quality Level A purchases made
under the PINGP system during the 5 years preceding the inspection.
Additionally, the inspectors reviewed maintenance work requests for
safety-related systems to identify maintenance activities that
required the use of replacement parts. From these reviews, the
inspectors identified numerous com)onents that had been installed in '
safety-related systems and those t1at had been placed in inventory i
for future use in safety-related applications. The inspectors then l
reviewed the specific component procurement record packages for these
items. The review concentrated on the three key issues given below
to determine if the component selection, procurement, receipt, and
dedication process (CGI's only) were appropriate to the
circumstances.
1. Were appropriate measures implemented to meet the 10 CFR Part 50,
Appendix B, Criterion III requirements for selection and
review for suitability of application of materials, parts,
equipment and processes that are essential to the safety-related
functions of systems, components and structures?
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2. 'Were' appropriate measures implemented to meet the 10 CFR Part 50,' -(
' Appendix B, Critorion VII requirements for assuring that. .
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equipment conforms lto the procurement documents with appropriate
provisions to ensure that objective evidence of quality is
furnished to the' licensee and. evidence produced by.' licensee
actions,1such as examination of-products' upon delivery, are
maintained to document that the requirements and specifications,
are met?
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-3.. .Were the requirements.of'10 CFR Part 21 imposed in' procurement- I
documents when-required for manufacturers / suppliers.to ensure as
a minimum that nonconformances or failures.to comply with ,
requirements would be reported to the licensee so that the l
licensee could evaluate such deviations in accordance with- ,
-section 21'.21 of 10 CFR Part 21?;
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The.NRC inspectors reviewed approximately 120 procurement. packages to
determine if each procurement was performed properly and to evaluate
the overall effectiveness of the'PINGP procurement program. Based on
the review of these packages,'the-inspectors found -instances of.
improper commercial grade dedications with inadequate or nonexistent :i
supporting documentation (testing, analysir. or inspection data) to :
ensure the CGI's were suitable for the inte h d applications.
B. Procurement Packace Review-Specific Examples of Procurement Intended
for Safety-Relatec Applications
1. The following are examples of Quality Level A purchase orders
1(P0's) for which the PINGP failed to imposeLthe requirements of i
10 CFR Part 21 on the vendor. This was also a-licensee identified :
violation and in accordance with 10 CFR Part 2, Appendix C, 1
Section V.G, no violation will be issued as a result of licensee
corrective actions taken. See Section II.B of the report for
clarification of this issue. -
a. P0 E26131 - Terry Corporation for throttle valves for the
AFW pump turbine- !
b. P0 E19716 - Limitorque Corporation, actuators j
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c. P0 E28767 - Limitorque Corporation, spare parts :
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d. P0 056510MQ - Foxboro Corporation, control equipment '
refurbishing services
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e. P0 D70038 - Henry Vogt Machine Company, gate valves for l
cooling water system
f. P0 E12778 - Westinghouse Electric. Corporation Company,
Minneapolis, shunt trip assemblies
2. Examples of Quality Level A commercial grade procurement used
in safety-related applications without adequate dedication
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. .The following examples were identified by the inspectors and j
discussed with licensee representatives. The licensee was q
requested to address the operability of each item due-to the ;
fact that no documentation existed to verify suitability for
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application. The safety functions and critical characteris- g ;
tics were not identified or verified. . During the inspection,
.the licensee addressed the operability of each item by
. performing a documented dedication using their Preliminary
Procedure N1 AW1 6.1.9, " Commercial Grade Procurement,".as a
guideline. This rationale addressed the suitability of
application for replacement items using the methods described.in
the procedure. j
The inspectors reviewed the documented commercial grade appli- I
cation evaluation and dedication justification performed by the
licensee during the inspection and determined that the identified I
CGI's in the plant appeared to be suitable for their intended-
applications. At the conclusion of the inspection, PINGP still
required the receipt of certain paperwork from vendors to
complete the dedication for the some of the items.
a. P0 029849 - Kunkle relief valves (1/2 and 1 inch) were
purchased " safety-related, QA1, off-the-shelf" from 1
Campbell and Seveys Inc., and installed in the emergency j
diesel generator'(EDG) starting air system. Receipt :
inspection was limited to identification and marking, i
physical damage and cleanliness. No documentation existed
that identified the safety functions and critical charac-
'teristics, or that would support their seismic qualifica-
tion. The relief valves were tested to verify their !'
pressure set-points and to check for seat leakage.
b. P0 D90497 - A 30-amp circuit breaker, purchased from the .
Westinghouse Electric Supply Company (WESCO), was installed ;
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in the safety injection pump heat trace system. No
analysis or test, was performed to support the suitability
of this item in a safety-related application. The licensee
had classified this item as a " safety-related, off-the-shelf"
procurement. Receipt inspection was limited to identifica-
tion and markings, physical damage, and cleanliness.
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c. P0 D43835 - Composite rupture discs were procured from BS&S
B Safety Systems /Simone Engineering and installed on the
AFW pump turbine exhaust header. The licensee classified
this item as " safety-related, off-the-shelf." The receipt
inspection performed was limited to the same level as in
item a and ) above, and did not include any dimensional or
material checks.
d. P0 E56979 - Foxboro model 62H relays were procured QA
Class 3, safety-related and were installed in the flux
tilt controllers. No documented basis for acceptability
existed, other than receipt inspections for identification
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and marking, physical. damage, and cleanliness. In this .i
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case, a post-installation test was performed in accordance 'l
- with a PINGP procedure to test the replacement relay i
operation. ;
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-The licensee' agreed to obtain a letter from Foxboro stating
that the relay procured is identical in form, fit, and
function to that of the original relay and that no process,.
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. design or material changes had been made.that could affect
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this item's seismic qualification.
e. P0 D62665 - A four-pole positive action switch was procured 1
from Foxboro Corporation as "QA 1, off-the-shelf".and i
installed in the main control board as a test switch for l
the fuel channel T-Hot input, without adequately evaluating
its suitability for its intended safety-related application.
Receipt inspection consisted of the same limited reviews'as
mentioned in the earlier examples.
f. P0_E30218 - A Square D model 9012 TP GAW-6 pressure switch- .!
for the Diesel Generator No.~ 1 starting air compressor was
purchased from the John Henry Foster Company and received l
only limited receipt inspection. The switch was rigidly l
mounted to the skid in a modified configuration using ,
normal bolting hardware and a unistrut channel as a base. '
No analysis'was available-to support the seismic qualifica--
tion of the new configuration. ;
g.- P0 092147 - The licensee purchased a mounting kit (Part No.
N0150RG) for a safety-)related
(PlantIDNo.IPT-430 installed onFoxboro pressure The-
the pressurizer. transmitter i
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transmitter (Type N-Ell GM) was purchased separately on P0
D27762MQ. The inspectors noted that no analysis or
documentation existed to support the seismic qualification
of the mounting bracket, which is safety-related, but .
procured by PINGP'as commercial grade. However, Foxboro 1
Parts List.008-548, dated November 1985,."N-E11 GM Elec- 1
tronic Gauge Pressure Transmitter for Nuclear Services !
Styles A and B," states, on page 4, that for the subject
mounting kit, the provisions of 10 CFR 21 apply, but for
the, mounting bracket only. All other parts are considered 1
commercial grade by Foxboro. This statement'in the catalog )
appears-to imply.that the mounting bracket is manufactured
under a quality assurance progran. and also meets the same
seismic qualification as Foxboro's. nuclear transmitter
line. The licensee agreed to obtain a' letter from Foxboro
clarifying this point.
h. P0 D09391 - The licensee procured a 5400 microfared commer-
cial grade capacitor from Solid State Controls Inc., for
use in the No. 21 inverter. Its suitability for its
intended safety-related application was not adequately
evaluated. Dedication was limited to receipt inspection
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for cleaniness, identification and markings, and physical
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damage.
. i ~. PO 069649MQ - A'2-pole,100-amp circuit breaker, procured
from WESCO, was -installed in the No.12 inverter., Dedica- <
tion-of this. commercial grade component was limited-to a ,
receipt inspection that verified identification markings'-
were' correct and checked for.. physical damage and
o, cleanliness..
lj. P0 QE35428 L Sixteen General- Electric (GE) type .THE'F136050: q
molded case circuit breakers were ordered from Lakeland: 1
. Engineering Equipment Company who, in turn, had them-
direct-shipped to PINGP from Bud Ferguson's Industrial .
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Control and Supply Company. This example is discussed.in
detail in paragraph-5 below.
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3. ' Molded Case Circuit Breakers
In light of the NRC's recent< inspection findings regarding
fraudulent and/or refurbished molded' case circuit breakers
(MCCB's),-aspromulgatedinNRCInformationNotice88-46andits l
Supplements 1 and 2 , particular emphasis was placed on this- '
area. -The inspection of this area at PINGP concentrated on
three facets of PINGP's practices regarding MCCB's:
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a. Evaluation of procurement procedures and their implementa-
tion to determine -(1) the adequacy for assuring quality
of replacement components and _ equipment for safety-related-
applications, and (2) the effectiveness of'the process in
identifying fraudulent material and preventing its use in
the plant, especially in safety-related plant applications. i
b. Determination of the status of PINGP's current-inventory of
MCCB's in terms of traceability to the original manufacturer,
.their condition, and reviewing MCCB purchase and usage <
history over the last several years.
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.c. Evaluation of PINGP's actions in response to Information
Notice 88-46, its supplements and any other correspondence
concerning fraudulent or refurbished MCCB's.
The inspector reviewed a computer printout of PINGP's entire. !'
inventory of MCCB's'in the on-site warehouse. This was compared
to the actual shelf stock of MCCB's as identified during a
detailed physical inventory and examination in the warehouse. ,
The emphasis was on MCCB's designated QA Class 1 which, '
according to PINGP's procedures, means that they were procured
in a manner consistent with their use in safety-related systems
and equipment. The inspector found over 40 items on the shelves
including (a) complete MCCB's, (b) MCCB's without their
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replaceable' thermal-magnetic trip units.or' lugs installed,
H (c) uninstalled trip units and lugs ~, and (d)'one MCCB-in:a.
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" half-cell" which, in PINGP's terminology, is a motor control
center (MCC) enclosure offone half the size of a complete motor. )
controller cell housing and which contains-an MCCB only. These 1
are used'as feeders for distribution par.els or subtier MCC's.. j
Of these components, there were 37 MCCB's with. tags identifying
them as QA1 material. ' Note that this total included a few
components which wouldLproduce a completed MCCB when assembled..
During this wareho'use inventory review, the NRC inspector. l
identified several discrepancies between.the computer inventory
printout and the actual stock including some item descriptions
and part numbers that were incorrect on the printout and one GE
type .TFK236225WL MCCB on the ' shelf (with a QA1 tag) that was not
on the inventory printout.
The items on the printout with incorrect part numbers and item;
descriptions consisted of (a) MCCB's that had been shipped. as
separate' frames,tripunits,andlugs(accordingtopacking
lists) but were identified as complete breakers, (b) trip' units-
only that were identified as complete breakers, (c) frames !
identified as complete breakers,-and (d) breakers with their.
trip units installed, but identified as frames only.-
The QA1 tag on the unlisted type TFK236225WL showed P0 A69399MQ
with no receipt inspection form (RIF) number. This purchase
order was one of a series of blanket purchase orders to Lakeland
Engineering Equipment Company (LEE) of Minneapolis.from whom
PINGP buys a large portion of their replacement electrical. j
components. However, this particular item was either deleted ;
from the inventory or may never have been part of it. The i
licensee was not able to determine the cause of these discre-
pancies during this-inspection, but is expected to correct them
and institute measures as appropriate to p_revent recurrence.
5. MCCB. Traceability
The second phase of the MCCB portion of this inspection was to
estab.lish, to the extent possible, traceability of MCCB's in the
warehouse to their manufacturers. In most' cases, the available
documentation, which consisted of purchase requisitions (called i
e " requisition requests" (RR)), P0's, and RIF's, could be used to
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establish traceability only to PINGP's immediate suppliers.
However, in the case of four MCCB's purchased from LEE, the
packing slips on file indicated that they had been
direct-shippedfromoneoftheirmanufacturer's(GE) warehouses.
One MCCB (of two received) on the shelf had come from'Graybar. '
Three purchased originally by PINGP's architect / engineer, Fluor ,
Pioneer, were shipped from a GE warehouse in Cincinnati, and the l
rest were purchased from LEE. For these, the files contained
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, on y LEE packing slip copies except for seven .GE THEF136050'- l
. breakers for.which'the file-contained'a copy of a direct- '
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shipment from another supplier. j
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cThese!seven' THEF136050 b'reakers were part of fan-order of 16 that i
had been purchased from LEE u'nder PO QE35428 in 1987. LEE had
W :obtained them from Bud Ferguson's Industrial Control and; Supply- )
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Company;of Whittier, California and.had them shipped directly_to
PINGP. The' packing _ slip / invoice from. Bud Ferguson's .showed that -
- 16 breakers had been shipped of which one was indicated on the
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packing' slip as "new" 'and 15 as "used." cTHEF136050 breakers-
have not.been manufactured. for about 13 years, but the .
documentation indicated they were needed because~of.their .
particular trip chara'cteristics in order to be compatible with-
L their individual feeder breakers for trip timing considerations. ;l
During the receipt process,-the 16 breakers were marked by the~-
licensee'with test specimen ~ numbers;"TS-l'through -16" for-
receipt testing. Of.thesevenontheshelf,six_(TS-2,4,6,
11', 13, and 15) were in boxes with labels that' appeared to be
photocopies of a GE label. The one marked "TS-3" had what
appeared to be an original GE label on its box. Except.for the-
, labels,:the' boxes were similar and contained similar packing
materials.
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TS-3 was probably the one that was considered "new" since_its
box label: appeared to be original. All the MCCB's had slots on
their, sides.(normal for type THEF). .However, the slots on the
apparently used MCCB's showed signs of tool scratches and
gauges, as did'the recessed holes for the' screws (and the screws
.themselves) that hold the front and rear halves of the case
together. Some anomalies had.been noted during testing of these
MCCB's that are discussed below.
Review of maintenance and installation documents-revealed that
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the other nine breakers were used or disposed of as follows:
Four were used for station battery chargers 11,L12, 21, and _22,
which are Class 1E (safety-related) loads. Two were used'as
. supply breakers in the MCC cells for safety-related motor oper-
atedvalves(M0V's)MV-32024andMV-32029,isolationvalvesfor l
feedwater to steam generators 12 and 22, respectively. .
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One breaker-(TS-7) originally selected for use with MV-32029
failed its post-installation testing (preventiv'e' maintenance
procedure PE-MCC-G7), although records indicated that it had
passed its' receipt testing by the same procedure. The instal-~
1ation/ testing electrician had locked it up in the shop to pre-
vent its use, but had not documented the failure or disposition
on the test form. Instead, it was indicated on work request
L8315-EB-Q for MV-32029 that the first breaker selected had not ;
tested within specifications. The MCCB in question was provided i
to the inspectors for examination, but its box was no longer
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7available.. It appeared to b'e'in the same condition as the othe'r
. ' "used" MCCB's_of this group.
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One of,the two. remaining MCCB's was used with the No. 122
l battery room 1 refrigeration. unit. (non-safety). . !The other was-
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used:as the supply breaker to AC distribution-panel 136,!one
load of which is for safety-related diesel _ cooling; water
pump 121.-
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'At,the exit meeting','the: licensee; committed to perform a safety-
evaluation of this, issue and prepare'a' justification for
continued operation for:NRC Region III-on.these MCCB's
installed in the safety-related -systems-identified above. '
6. MCCB Dedication 4
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PINGP's' dedication ~of commercial grade MCCB's'for safety-related- -
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or QA1. service was-reviewed. The review included procedures and >
their implementation, test' methods and' practices, : specifications j
and_ test results. Upon completion of this review, the NRC
-inspector identified deficiencies in the following. areas::
a. PINGP's present program for upgrading-'commmercial grade ~.
MCCB's does not include'the essential elements-needed for . :
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an effective' dedication program. ' Establishing documented (
traceability of MCCB's to their original manufacturer is !
not required by':the PINGP program, and'in-most cases was
not accomplished.- Furthermore, the program does not assure
an adequate review for suitability for safety-related-
applications in terms of (1) defining safety functions,
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(2) determining critical characteristics,'and-(3) design
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'and manufacturing history review to verify continued !
suitability._ This part of PINGP's program is' limited to
part number and catalog specification verification'only. '
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b. The receiving 3rocess does-not subject commercial grade
MCCB's, even t1e few that may be traceable to the manufac- o
turer (but fabricated without benefit of a 10 CFR Part 50, {
Appendix B quality assurance'(QA) program), to inspection
and. testing sufficient ~to provide reasonable; assurance that
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the MCCB's will perform their intended safety. functions l
under all expected service conditions. . Receipt inspection !
consists only of checking part numbers and quantity'and !
inspecting for damage and cleanliness. Testing upon ;
receipt or prior to release for' issue is not done and/or l
documented consistently for all QA1 MCCB's, although PINGP l
stated that maintenance procedures call for all MCCB's,
whether or not receipt tested, to be post-installation
tested. Some documented evidence was reviewed that con- I
firmed this practice for the examples identified. j
c. Receipt testing (when it is done) and post-installation !
MCCB testing consists of performing the'MCCB portion of
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m4 ,PINGP Preventive Maintenance Procedure PE-MCC-G7. This. 1
procedure included only a. test of the thermal overload trip
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function'at 300% of rated nominal load. 'The instantaneous
_. magnetic trip function,.which is provided for'short circuit
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protection, iscnot tested-(and cannot be with PINGP's test
equipment). This test, among others, is recommended as_a
minimum functional' verification by GE MCCB application
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guide GEJ2779G,. National Association of Electrical
D Manufacturers (NEMA)StandardAB_1-1986(Section6), NEMA.
MCCB field inspection and performance verification
-procedures (NEMA AB 2-1984), and Underwriters Laboratories
(UL) Standard 489.
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-When used as 'the supply breaker for an MCC cell, the MCCB's
instantaneous magnetic trip function is often the only
-short circuit or ground fault protection provided. Also,
the motor starter / controller has its own thermal inverse
- time overload trip device.to provide protection for
sustained motor overload-conditions. ;
The inspector asked PINGP to explain the technical- basis
for'PE-MCC-G7 and how PINGP technically justifies use of
this procedure alone for-dedication of commercial grade
MCCB's for use in safety-related applications. In
response, the licensee stated that the current version of
PE-MCC-G7 was based on a NEMA AB1-1975 field test.
However, upon reviewing that test, the inspector found!that ;
the continuity check aortion (in section 2.38) was omitted {
as was much of the otler testing prescribed by current ;
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industry standards.
Review of individual test records revealed.some deficien- q
cies in test control and test practices. Some procedures l
did not contain correct acceptance criteria in terms of
trip time limits for various types of MCCB's and at various
test values of load (multiples of nominal trip setting).
The wrong specifications were chosen from the procedures on
occasion. No Engineering or QC checks of test preparation
or conduct was evident from the records. Data sheets were ,
filled out inconsistently (not always in accordance with !
the clear intent of procedure), and there was no review by l
QC or Engineering documented in the place indicated on the j
data sheets.
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The following are examples of testing deficiencies identi-
fied during the inspectors' review of MCCB testing: 4
GE type THEF136050 MCCB's purchased from LEE under P0 I
E35428 and received under RIF 18740 on direct-shipment I
invoice 5604, dated April 13, 1987, from Bud Ferguson's l
Industrial Control and Supply, were improperly tested under l
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the revision of PE-MCC-G7 in effect at that time. The time j
l specification of 33 to 80 seconds for 300% trip current
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(150 amps) recorded on the test form was erroneously chosen
from the 104 F ambient temperature column of G7's Table 1
(coveringGEMCCB's). Since the ambient temperature
recorded for the test was 75 F, the values of 50 to 110
seconds should have been chosen from the 77'F column. As a
result, one pole on test specimen TS-2 having tripped at
49.1 seconds,andallthreepolesonTS-5(at40.6,45.9
and 45.5 seconds) were out of specification (low). These
particular breakers were chosen to avoid breaker coordina-
tion problems, but out of specification trip timing could
contribute to these problems. This condition was not noted
on the test record and reviews and dispositions of the
anomalies were not documented.
II. QUALITY ASSURANCE AUDITS
The inspectors reviewed the licensee's quality assurance (QA) audit
program of ver. dors of safety-related materials, equipment, and services.
Vendor audits for the PINGP are the responsibility of the Power Supply
Quality Assurance (PSQA) group of the licensee, headquartered in
Minneapolis, Minnesota. These audits are performed utilizing a
combination of PSQA personnel and private consultants. A review of the
1988 PSQA audit schedule identified a total of 137 audits scheduled to be
performed. The results are used to maintain and update the Operational
Quality Assurance Vendor List (0QAVL). The 0QAVL identifies those vendor:
evaluated by PSQA as having an " Approved" QA program that is acceptable to
the licensee. Vendors which are conditionally approved, inactive, in a
review stage, or scheduled for auditing may also be included on the list
with appropriate noiations.
The 0QAVL includes vendors selected and approved based on several factors
including acceptable past performance through PSQA vendor audits, quali-
fication as an ASME Nuclear Certificate Ho' der, and satisfactory results
of CASE and licensee approved architect / engineer surveys. Prior to
approval, the vendor's QA program is reviewed and implementation verified.
The review consists of verification that the vendor's program complies
with the applicable requirements of 10 CFR Part 50 Appendix B or ANSI
N45.2-1971. Implementation of approved and conditionally approved vendor
QA programs are verified 1nitially and triennially thereafter. This
verification usually consists of an on-site audit intended to verify
continued, effective QA program 1 implementation and may be supplemented
periodically as determined by PSQA. The licensee has established three
quality levels for procuring items which affect nuclear plant operations.
Quality Level A pertains to QA or safety-related items with the exception
of fire protection items, Quality Level B is for fire protection items,
and Quality Level C is for non-QA items. If the procurement of an item is
determined to be Quality Level A, the program provides for three
" approaches for assuring quality" using suppliers in one of the following
categories:
1. Approved Su) plier - This a)proach may be used when procuring from
vendors witi QA programs t1at comply with the applicable requirements
of ANSI N45.2-1971, 10 CFR Part 50, Appendix B or its equivalent, and
have been approved by PSQA.
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2 .- . Verified Su) plier - This approach may be used when procuring from-
suppliers tlat are not approved, provided certain provisions are
specified to verify the quality of ~the item.
3. Commercial Grade-- This approach may be used to procure items which
satisfy the 10 CFR Part 21 definition of commercial grade. This
approach was p.reviously referred to by the licensee as
" safety-related off-the-shelf"' procurement.
Items which are not simple or standard in design and manufacture may also
require a certificate of conformance from the supplier. In a few a
instances noted, procurement from approved suppliers received additional
verification such as source surveillance or post-installation testing.
The licensee relied on this additional verification as an adequate basis
for dedicating CGIs.
A. ' Establishment and Maintenance of the 0QAVL
The 0QAVL is issued to the PINGP procurement staff to purchase
material, equipment, and services for-structures, systems, and
components requiring quality assurance as specified in the PINGP QA !
manual.. The inspectors selected over.40 vendors listed on the 0QAVL-
which correlated to procurement packages selected by the inspectors ,
for review. The' vast majority of vendors reviewed were- categorized !
by PSQA as Approval.. Codes 1 and 2, which indicate an approved and
conditionally-approved vendor. Several of the vendors reviewed were
strictly suppliers of CGI's. PSQA complied with PINGP procedures for j
-establishment and maintenance of vendors on the 0QAVL with one excep- i
tion noted: Woodward Governor Company was allowed-to remain on the !
0QAVL from August 1985'until. September-1986 (when it was removed from !
the 0QVAL) without receiving a triennial audit. The vendors reviewed ]
were primarily used by the licensee for Quality Level A purchases 1'
which are used in safety-related applications. Requests for an
a? proved supplier to be incorporated on the 0QAVL are initiated by .
tie PINGP site procurement staff. j
B.. 10 CFR Part 21
i
During the procurement package review the inspectors identified (see
Section I.B.1) several procurement for Quality Level A items,
purchased from suppliers approved utilizing the approved supplier l
approach to assure quality, that failed to impose the requirements of
PINGP Form 3-3096, on these suppliers. This form establishes the QA
requirements for approved suppliers and also includes a paragraph
imposing the requirements of 10 CFR Part 21 on the supplier.
In response to this finding, PINGP produced a copy of an internal
audit report performed by Nuclear Operations Quality Assurance (N0QA)
in February 1987 (Finding No FG 87-5) which identified several PINGP
P0's placed on approved suppliers which did not include Form 3-3096
or list applicable QA program requirements. PINGP's corrective s
actionwasto(1)revisetheaffectedP0's;(2)reviewopenorders,
and; (3) send letters to all procurement requestors highlighting this
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omission. Corrective action was not undertaken to review all closed
P0's(items.already shipped and received by PINGP).
The NRC inspectors expressed concern over the omission of form
3-3096; however, P0's identified during the inspection were all
issued before N0QA self identified this deficiency. The
NRC-identified P0's included the following:
P0 Supplier P0 Date
i
E26131 Terry Turbine December 12, 1986 I
E19716 Limitorque October 6, 1986 i
E28767 Limitorque January 21, 1987
D56510MQ Foxboro September 30, 1984 i
D70038 Vogt Machine March 21, 1986 '
E12778 Westinghouse July 18, 1986
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It appears that these P0's were assumed closed at the time of the
N0QA finding since they were not listed in the N0QA audit report.
III. LICENSEE / VENDOR INTERFACE
A. Processing of Incoming Vendor-Related Information i
The inspectors reviewed the licensee's system for receiving, tracking,
and' evaluating incoming vendor _information. Specifically, the !
inspectors reviewed the processing of technical information received
from Westinghouse Colt Industries, the Institute for Nuclear Power
Operations (INP0),, the NRC, and vendors of safety-related equipment
and components.
The vendor interface programs at the PINGP are established by.the
licensee's corporate and plant specific directives. The controlling
directives, instructions and procedures are:
N1ACD 10.3 Operating Experience Assessment
5ACD 3.7 Operating Experience Assessment i
5ACD 3.6 Reporting
5AWI 3.3.3 Action Item Tracking System
SAWI 3.6.1 Investigative Reports for RE's and SOE's
3NTS 3.2 Operating Experience Assessment Program
- 3NTS 3.1 Nuclear Network Screening Guide
Corporate Nuclear Administrative Control Directive N1ACD 10.3 states
that the assessment of vendor and operating experience is accomplished
through two programs. INP0 communications and operating events for
the licensee's nuclear plants are assessed by Nuclear Technical
Services (NTS) procedures while all other vendor, regulatory and
operating communications are assessed by the plants' Operating
Experience Assessment Programs. The individual plants' Operating ,
Experience Assessment Programs also include the processing of incoming
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10 CFR Part 21 notifications. The PINGP Operating Control Assessment
Program is delineated in Administrative Control Directive SACD 3.7,
Operating Experience Assessment. This is the assessment program and
its implementation reviewed during the inspection.
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~The scope ~of the plant assessment program includes;most regulatory-
i- and vendor experience information except for INP0-provided
^information. Information received at the plant by the Plant
Manager is forwarded.to the Staff Engineer for action.::The-
Staff Engineer or a qualified designee screens the-information
for applicability;to the plant.. If the information is deter-
mined:not to be applicable, _no further action is taken. If
it :is determined that the. information is' applicable, .it is
forwarded to the appropriate organization for formal assessment
and action by a qualified individual. If.the required action
cannot be performed immediately, it may.be-input to the plant
action _ item system for tracking. The results of the screening
and assessment are documented on PINGP Form 536,:which is
maintained and the status. tracked'by the_ Staff Engineer.
Theoretically, the process described'above should accomplish its ,
purpose. However, deficiencies in implementation were identi- !
fied that could.be corrected by strengthening the program
guidelines. 'Specifically, the directive-does not provide
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experience criteria for.the qualified reviewers, nor does the
directive provide guidance on!the level of documentation that
should be included with the assessment form.- Additionally, ;
screening and assessment of this information by Staff Engineers i
and their supervisors was not sufficiently detailed. Specific " R
examples are provided in later sections of*this report. i
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B. Vendor Technical Information 1
Approximately 40 vendor issues were reviewed by the inspectors to
determine the adequacy.of the screening and assessment process. The-
vendor issues reviewed included Westinghouse Technical Bulletins and
letters, IE'and NRC Information Notices, incoming 10.CFR Part.21
notifications, INP0 SER's, and other vendor issues. Additionally, 17 ,
Colt Industries /Fairbanks Morse Engine Division. (FMED) emergency !
diesel generator Service Information Letters were reviewed. Some of
the vendor issues were selected from the plant Operating Experience
Assessment Log. Several other notices that should have been received
, ,
at the plant, but were not included on the log, were requested to-
determine if they were received and appropriately addressed. These
. included the Colt /FMED Service Information Letters. During discus-
sions with the licensee, it was siiscovered that contrary to plant
directives, not all vendor issues are reviewed by the Operating
Experience Assessment Program. The plant system engineers in some
instances received information directly from vendors that bypassed
the Operating Experience Assessment Program.
The inspectors found that 16 of 40 issues reviewed were not appli-
cable to PINGP. Twoissues(11etters) could not be found and four
issues that had been addressed were not included in the assessment
_ program. In most cases, the documentation included with PINGP Form
536 did not contain sufficient information for the inspectors to
determine if the assessment was correct. The inspectors had to
request additional information for several issues in order to deter-
'
mine the adequacy of the assessments. Specific concerns related to
the assessments are described in later sections of this report.
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During-the inspection, the NRC inspectors held' discussions withj
"~ s licensee personnel and performed' procedural reviews that' addressed-
the interface between the licensee'and its vendors. As a result, the
inspectors determined that the licensee has not established a formal. .
interface _ program with vendors other'than Westinghouse, the NSSS
supplier. That is, the licensee lacks a formal: program for inter- !
-facing with the Class 1E switchgear and emergency diesel-generator '
suppliers. In addition, the licensee has-not established a program
for periodic contact with vendors of key safety-related components,
as identified by the licensee.
C. NSSS Interface
'
The inspectors reviewed a sampling of the licensee's disposition of
Technical Bulletins and letters received from Westinghouse. The NRC
inspectors identified concerns with the screening and assessment of
the following Westinghouse Technical Bulletins and letters discussed
below:
1.- Westinghouse Technical Bulletin 85-18, Revision 1 & 2 was . i
issued to alert licensees that electrical solenoid valves and
supporting equipment used for isolation of main feedwater.may
require specific. qualification requirements depending on their.
function and location. For some applications,.the main and
bypass feedwater control valves.provPle a backup isolation .
function to the main feedwater isolation valve to satisfy the.
single-failure criterion.' Redundant nonsafet i
functions are allowed as backup (NUREG 0138) y-related
to a single isolation
sufety-
related isolation valve in'the Westinghouse feedwater system.
The bulletin went on to describe a situation where a steam line
breal in the proximity of the feedwater flow control valve had ~
the potential to affect the closure capability of this valve.
If this situation existed at the recipients plant, environmen-
tally qualified equipment should be installed or alternative
actions considered.
At the PINGP, the. architect / engineer, Fluor Pioneer, did take
credit for the flow control valve as one of the redundant non-
safety-related backups to the isolation valve. However, it was
in a location where it could be affected by a steam.line break.
Nevertheless, the. licensee, determined that this was a redundant '
nonsafety-related function and, therefore, qualification of the-
equipment was not necessary. This assessment was incorrect,
however, because the licensee failed to consider that the
nonsafety-related redundant functions had to be maintained to
act as a backup to the single safety-related isolation valve, as
described in NUREG-0138 and the facility FSAR, Appendix I.
Based on the above, these valves should be environmentally
qualified.
2. Westinghouse Technical Bulletin 84-06 describes a condition in
which auxiliary feedwater (AFW) delivered to the steam generators
was less than that required to meet the plant design basis for a
loss of normal feedwater accident. The bulletin recommended that
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the procedures used to verify the AFW flow rates measured be l
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consistent with the pressure conditions specified in the design
criteria. This issue was screened by the licensee and deter-
mined not to be applicable because discharge pressure used in ,
the surveillance is consistent with the design criteria. The '
current revision of the annual flow test performed during
startup did not provide any criteria for measuring AFW pressure.
The surveillance used at the time the bulletin was received did ,
include a step for recording pump discharge pressure, but was i
not'necessarily consistent with the design criteria. The i
surveillance did not direct the operators to perform the test
against a specific pressure in the steam generator or ensure
that the data were consistent with the pump curves. l
1
The data obtained from surveillance performed in 1984 were !
sufficient to assure the inspectors that the system could
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perform its intended function, but the surveillance as currently l
performed no longer provides this assurance. The licensee
committed to revise the procedure for AFW flow testing to
include specific criteria for establishing pressure as well as
flow.
3. On June 25, 1987, Westinghouse issued a letter concerning a . ,
recommended modification to the component cooling water system i
(CCWS), the design of which could potentially violate contain-
ment isolation capability. The letter was issued to correct a
Westinghouse recommendation made several years before that the
CCWS be modified to prevent a potential overpressure condition
in the system piping. The earlier modification involved main-
taining a continuous vent path from the CCWS surge tank by l
removing relief valve internals or disabling the tank isolation j
vent valve. A Westinghouse plant that performed this modifica-
tion subsequently found that the containment isolation require-
ments of General Design Criteria (GDC) 56 and 57 were violated.
In the later Westinghouse recommendation, licensees who performed
this modification were advised to review their plant design to
determine if the violation modification resulted in the violation
of their containment isolation criteria.
During the screening and evaluation process, the licensee deter- {
mined that the matter was applicable to PINGP. This was based i
on a section in the plant updated FSAR which stated that any
containment leakage to the atmosphere through the CCWS would be
minimized because of the pressure head of water in the system
piping. The screening and evaluation did not address whether ,
the modification had been performed or whether, if performed, it I
affected the plant design basis for containment isolation
features, and therefore, was deemed to be inadequate by the ;
inspectors. The NRC inspectors found that the modification had i
been performed; however, the plant had been designed such that j
redundant isolation valves were installed and the plant still i
met the requirements of GDC 56 and 57.
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D. Emergency Diesel Generator Interface
The PINGP has two emergency diesel generators (EDG's), designated as
D1 and D2, to support emergency-type loads in the event of the loss
of offsite power. The diesels were manufactured by Colt Industries /
Fairbanks Horse Engine Division (Colt /FMED), Model 3800 TD 8-1/8, l
rated at 3000 kw. The governors were manufactured by Woodward <
Governor Company, Model UG8. The operational time accumulated on the
D1 and D2 diesels is 1616 hours0.0187 days <br />0.449 hours <br />0.00267 weeks <br />6.14888e-4 months <br /> and 2274 hours0.0263 days <br />0.632 hours <br />0.00376 weeks <br />8.65257e-4 months <br />, respectively, at the 4
time of the inspection. ;
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1. Review of Colt /FMED Manuals 1
!
The inspectors reviewed the following manuals that are appli-
cable to the EDGs:
Plant Operations Manual, Section D18 " Equipment Lubrication"
Rev. 24, dated August 24,1988;p.9 ford 1andD2(Lubeoils
for diesel)
- Technical Manual, No. X-HIAW 28-44, " Emergency Diesel
Generator Set," Rev. 15, Fairbanks Morse engine and Woodward
governor
- Service Manual, "3800 TD 8-1/8 Engine Generating Set and
Accessories"
The Service Manual included most of the Service Information ;
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Letters (SIL's) from Fairbanks Morse which are applicable to the
licensee's EDG's. OneSIL(C-1,datedNovember 15, 1984) that
was applicable to the PC Model diesel was erroneously included,
and missing were SIL's A-7 and A-17, dated December 16, 1985 and
April 22, 1988, respectively. The manual also had information on
diesel accessories including information from Colt Industries,
Nugent filters, Class 9012 pressure switch 112AS, and various
Quincy items. However, the information had not been inserted in
the proper manual location by pen-and-ink changes to assure that
the maintenance personnel would be aware of the change without
rereading each vendor letter. In discussions with licensee
personnel, the inspectors learned that the receipt and
disposition of incoming vendor information were treated in a
fragmented manner. Not all the information received was passed
on to the EDG system engineer. 'Some was sent directly to the
Manual Custodian, and, as a result, no tracking system was
established to assure all items of information were identified
and properly handled in a timely manner.
The inspectors also reviewed EDG Annual Inspection procedures,
PM 3001-2-D1, Rev. 2, and PM 3001-2-D2, Rev. 2. It was noted
that in some cases the procedures included appropriate steps in
the annual inspection process consistent with items identified
in the vendor's SIL's. Included were timing chain inspection
(SIL A-11), blower lobe inspection and clearance readings (SIL's
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'A-1 and A-8), vertical drive inspection (SIL A-9), and inlet air 1
checkvalvelubrication.(SILA-3). j
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The _ inspectors. concluded that the licensee's system.for proces- l
?
Esing EDG_ vendor provided information should be resiewed and- .j
improved to assure lthat all such information is properly j
evaluated and-implemented in the appropriate manuals when i
required.
<
2 '. - Review of Colt /FMED SIL's and R&SI's
The inspectors reviewed the Repair and Service Information
(R&SI) and the SIL's issued by Colt /FMED that were applicable to
the licensee'.s EDG to determine whether they had been properly
considered and implemented. The applicable documents. consisted
of 15 SIL's_(A-1 through A-17'with the exception of A-6 and.
A-10) and seven R&SI's dated April 22, 1971 to April.18,'1980. i
The licensee's; procedure to' handle such matters, as previously ;
. discussed, involves use of the Operating Experience Assessment "
.(0EA) (PINGP Form 536,-Rev. 3) to evaluate an operating experi-
ence document and to identify necessary corrective action.
While_there was minimal evidence that some of the matters had
been addressed in the work request log, the documented evalua-
tion for applicability to PINGP using the OEA forms had not been
completed; in fact they were initiated and completed during the
the last week of the inspection and made available to the
inspectors for review. However,'no forms were made'available
for the seven R&SI's. Based on the completed OEA forms. it was
determined that.some of the corrective actions for the SIL's
. involving hardware changes, procedural changes, parts list
( changes, and other manual changes still have to be performed. In
several instances, Work Requests were identified under which
some of the necessary corrective actions had been completed.
In SIL A-17, dated April 22, 1988, Colt /FMED recommended that
flexible hoses in the fuel crossover pipe be changed to pipe.
assemblies made of steel tubing to avoid the risk of potential
fire. The licensee had not received, evaluated, or implemented
the recommended modifications in the SIL at of the time of the
inspection. The inspectors gave a copy of the SIL to the
licensee; and, following an evaluation, the licensee committed
to implement the recommendation by November and December 1988 on
the D2 and D1 engines, respectively. ,
This situation in which PINGP had not received a SIL applicable
to them, is why licensees need to establish formal interface
with their EDG vendor, as well as -informally contacting key
vedors of safety-related components.
The Production Engineer responsible for all aspects of the D1 ;
and D2 diesels indicated that many hardware modifications have j
been made to the diesels over the years based on recommendations j
from the vendor representatives. However, these recommendations i
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are not always reported.by the vendor through the SIL/R&SI
.- system. The modifications'made in'this manner can be identified
through the licensee's work request log.
The inspectors concluded that the licensee had not performed'
complete and. timely eva_luations of all the EDG vendor-provided
_
information as described in procedure.PINGP 5ACD 3.7, l
l ~ " Operating Experience Assessment."
3. NRC Information Notices Affecting the EDG's
The' inspector selected 12 of the most recent information notices
applicable to the EDG's to determine whether the licensec had
evaluated and implemented any necessary action. The licensee
demonstrated evaluation of each information notice by means of a
-completed OEA form. The inspectors concluded that the licensee
was. adequately considering and implementing the information , ;
L , notices potentially applicable to the EDG's in a timely manner.
o
4. Procurement of fpare and Replacement EDG Parts
The licensee issued' Administrative Control Directive SACD 2.1,
Rev. 7 on August 30, 1988 that identifies the safety-related
structures, systems and components at PINGP. The diesel l
generator and major subitems are included on the Q-List. To
- further define components, the licensee has established a Q-List
by system and component that identifies all the safety-related
items on the D1 and D2 diesels. The list consists of 255 items.
Spare and replacement parts for the. diesels are primarily
purchased from Colt /FMED and Woodward Governor.
The inspectors reviewed several purchase order (P0s) for many
items including bearings, valves, filters, hoses, gaskets,
thermocouple, bolts, manifold covers, and springs. In all
cases, the requisition request identified the procurement as a
Quality Level A procurement, and the purchase order required the
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submittal'of a certificate of compliance (C0C) to specify that
the parts are supplied under the specifications of original
purchase order X-HIAW 28. The P0's also required that the
supplier have a quality assurance program that meets ANSI
N45.2-1971, 10 CFR 50 Appendix B or equivalent and has been
accepted by the licensee, and that the supplier must meet the
requirements of 10 CFR Part 21-for the reporting of defects.
E. Incoming 10 CFR Part 21 Reports and Vendor and NRC Correspondence
The inspectors reviewed the licensee's assessment of several Part 21
reports and vendor letters to determine whether the licensee had
taken appropriate action. Some of the-letters sent to the licensee
were not specifically identified as Part 21 notifications as was
stated in vendor notifications to the NRC. These letters, however,
did alert the licensee that they should be assessed for potential
affect on the plant. The inspectors also reviewed a limited number
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of licensee assessments of NRC cortaspondence possibly affecting- {
equipment at the PINGP. Assessments that were not adequately per- ,
formed-are described below.
-1. -An4 Anchor / Darling ~1etter, dated December 10, 1985, was sent.to i
licensees,' including PINGP, describing'a problem of valves with '
>issing lock welds at the hinge support / bonnet interface.
Anchor / Darling indicated that the PINGP had received valves that.
could be effected by the problem. The licensee could not find
any record that it had received.this letter. During the inspec-
tion, the licensee assessed the matter and determined that some '
of the suspect valves were being used at PINGP but only in non-
safety-related systems. No immediate actions were required.
-This is a good example why licensees need to informally contact
key vendors of safety-related componets and establish an inter-
face for receipt of technical information. ,
2. Target Rock Corporation issued.a letter, dated May. 31, 1988,
describing a problem with cracking of the insulation on lead
wires for position indicator switches, that could affect posi- ')
tion indication on Target Rock solenoid valves. . Target Rock '
recommended that the position indication switch be replaced if
evidence of. insulation cracking .is noted. The licensee evalua-
tion stated that the valves were used at PINGP as head vent
valves, but since the position indication switches were not
safety-related, no actions were _ required at .this time. The
licensee did not" address'the environmental qualification aspects
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of the valves and position indication switches in the OEA '
assessment. . The NRC inspectors discovered that the valves were ;
on the EQ list, but the position indication.swiches were not '
included, nor were they listed in the licensee's submittals in i
response to Regulatory Guide 1.97. The inspectors concluded q
that the licensee's screening assessment and evaluation was j
' incomplete because it did not consider the EQ aspects of the
valve; however, no requirements were violated.- l
3. The Tube Turns Division of.Chemetron Corporation issued a letter
on June 6,1980, which discussed potential problems of. mixed -
heats of steel on 4-inch pipe elbows and 2-inch tees. The !
letter listed PINGP as one of the plants being investigated and j
stated that the results were complete for PINGP. The licensee
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could find no record of action on this letter during this
inspection. However, the initial assessment indicated that PINGP
was not affected and the licensee stated they would continue to
investigate. This is another example of why licensees need to
establish informal contacts with their vendors.
4. Ganina-Metrics (G-M) issued a 10 CFR Part 21 notification, dated i
May 10, 1988, concerning the environmental qualification of the
ex-core neutron flux detector system. The Part 21 notification
' identified test failures of the cable conduit system that j
resulted from porous solder joints that would allow moisture
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intrusion under simulated BWR, in-drywell loss-of-coolant- )
accident (LOCA) test conditions such that signal integrity and
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instrument performance would likely be unacceptably degraded.
The detector provides post-accident monitoring (PAM) capability
for reactor core neutron flux as required by Regulatory Guide
1.97 which also requires the instrumentation for this parameter
to be environmentally qualified.
NRC Generic Letter (GL) 88-07 instructed licensees to take
certain actions when qualif hd equir t h found, or suspected
of being, unqualified. The PINGP evaluation (under Action Iten
0415) of the G-M 10 CFR Part 21 report and subsequent actions
were considered inadequate in that the requirements of GL 88-07
were not met, including prompt determination of operability),
preparationofajustificationforcontinuedoperation(JC0
and evaluation of technical specification considerations and
deportability.
Prompted by the NRC inspector's inquiry into this matter, the
licensee prepared a safety evaluation (No. 250, dated
November 4, 1988) that addressed the GL 88-07 concerns with
regard to the questioned environmental qualification of the G-M
neutron detewors' cable conduit system, including a JCO. This
safety evalv tion was provided to the NRC inspectors for review
shortly before the exit meeting. The brief, preliminary review
that was accomplished in the limited time available, together
with additional information on testing margins requested by the l
inspector, indicated that there was no immediate safety concern.
However, the inspectors concluded that this was an example of an
inadequate and untimely review of an incoming 10 CFR Part 21
notification.
5. IE Information Notice 84-83, was provided to alert licensees of
the potential for significant degradation 'of safety associated
with various battery-related problems. The notice describes the
circumstances contributing to battery problems and recommends
preventive measures. The licensee's assessment of this " ,
stated that it was not applicable because the license" ao %n
aware of these problems for many years and had taken
corrective / preventive measures. The licensee's procedures in
effect at the time of the notice were reviewed and contained
none of the recommendations suggested by the notice. The
licensee told the inspectors that the preventive measures
implemented were based on recommendations contained in INP0
operations and maintenance reminder (0&MR) 308. Some of these
recommendations were not implemented until 1988. This is
another example of an inadequate OEA screening and evaluation.
6. IE Information Notice 88-46 and Supplement 1 were icsued to
alert licensees of defective circuit breakers reported by
another licensee. The inspectors reviewed the PINGP evaluation
and actions in response to the information notice and its
supplement and found them to be inadequate. Although, the
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licensee's OEA form for this item, dated August 8, 1988, stated
that none of the subject breakers were at PINGP, the inspectors
identified several examples of similar Westinghouse models
(differing only in trip setting) and one example of a GE (type
TFJ) MCCB of the same model listed in the notice.
A similar disposition was made for Supplement 1, as documented
on an OEA form dated August 15, 1988, but the inspectors identi- ,
fied many MCCB's at PINGP that were similar to the ones listed '
in the notice and one model THED136100WL, which is one of the
particular models listed in the supplement. The licensee stated
that it would re-evaluate the notice and its supplement and
identify all the a,ppropriate circuit breakers at PINGP.
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APPENDIX A
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I.. PERSONS CONTACTED:
A. Northern States Power Company ;
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R. Hansen, Procurement Engineer
E. Watzl, Plant Manager
? M ndele, PlanttSuperintendent, Engineering and Radiation Protection
A. m >1l, Superintendent,. Technical Engineering
M. le , ', superintendent, Quality Engineering
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L -mpleton, Quality Specialist '
'J. t,raig, CYGNA l
G. Fehr, CYGNA
A. Fakhar, CYGHA
T. Maxey, -Tenera
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R. Desautels, Tenera .i
A. Hunstead,' Staff Engineer
J. Shuelke, System Engineer ;
G. Miller, Superintendent, Operations Engineering l
J. Daley, Plant Administration Specialist '
G. Eckholt, Engineer
-J. Johnson, Plant Office Manager }
M..Wadley, Shift Manager
'D. Brown, Fire Protection Engineer
R. Oelschlager, Environmental Qualification Engineer i
R. Pearson, Senior Production Engineer
J. Pederson, Production Engineer.
S. Hiedeman, Production Engieer
G. Gerl, Production Engineer
E. Burke, Production. Engineer
D. Lortscher, Purchasing and Inventory Control Superintend:nt
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B. Nuclear Regulatory Commission
- H. Miller, Director, Division of Reactor Safety, RIII l
- U. Potapovs, Chief, Special Projects Inspection Section, VIB i
- D. Dilanni, Project Manager, HRR !
- J. Hard, Senior Resident Inspector !
- H. Moser, Resident Inspector l
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- Attended exit meeting
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APPENDIX B
PROCUREMENT PROCESS AND PROCEDURES
The procurement of material, equipment, and services at Prairie Island Nuclear
Generating Station (PINGP) is governed by the procedures listed in this appen-
dix. When the need for procurement of material or services is identified, the
cognizant system engineer will cause a requisition request (RR) to be prepared
listing all technical and quality assurance (QA) requirements. The RR is
reviewed and approved by the appropriate department head with QA concurrence.
Any engineering evaluations that are required are prepared by the onsite
engineering support organization. The purchasing department, headquartered at
the Northern States Power Company corporate offices in Minneapolis, Minnesota,
enters the information into its coinputer and produces a computerized document ,
called a purchase requisition (PR). The PR is reviewed for accuracy and is l
signed by the appropriate level of management, depending on the cost involved. l
The purchasing department then prints out the information on a purchase order
(P0) form for dispatch to the vendor.
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It should be noted that materials, equipment, and services (including replace-
ment components and piece-parts classified by PINGP as Quality Level A/ safety-
re'sted/0A1) are subject to the requirements of 10 CFR 50, Appendix B, " Quality
Asstrance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" and
10 CFR Part 21, " Reporting of Defects and Noncompliance." It should also be
noted that these requirements apply to facilities licensed under 10 CFR Part
50, regardless of the original basis or quality assurance standard under which
the facility was constructed.
A facility licensed by the NRC under 10 CFR Part 50 may choose to procure
parts, equipment, or services for use in safety-class applications from vendors
who lack a QA program that complies with 10 CFR Part 50, Appendix B. The
facility must then institute its own measures to ensure that the procured
materials are of adequate quality and capability to perform their
safety-related functions under normal service and seismic and harsh
environmental conditions.
In the course of inspecting the licensee procurement program and its
implementation, the NRC inspectors reviewed the following corporate level
procedures:
NSP/PINGPAdministrativeControlDirectives(ACD's):
N1ACD 6.1, " Uniform Nuclear Procurement Process"
N1ACD 6.3, " Material Control"
NSP/PINGP Corporate Administrative Work Instructions (AWI's):
N1AWI 6.1.1, " Procurement Overview"
N1AWI 6.1.2, " Internal Procurement"
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N1AWI 6.1.3, " Planning Procurement of Services"
N1AWI 6.1.4, " Planning Procurement of Items"
N1AWI 6.1.5, " Requisition Contents"
N1AWI 6.1.6, " Procurement of Fuel"
N1AWI 6.1.7, "Use of Approved Supplier"
N1AWI 6.1.8, "Use of Verified Supplier"
N1AWI 6.1.9, " Commercial Grade Procurement"
N1AWI 6.1.10, " Quality Level B Procurement"
N1AWI 6.1.11, " Receiving Planning Activities"
N1AWI 6.1.12, " Source Verification Activities"
N1AWI 6.1.13, " Purchase Requisition Processing"
N1AWI 6.1.14, " Blanket Purchase Orders"
N1AWI 6.1.15, " Receiving Activities"
The following site procurement procedures were also reviewed:
PINGP ACD's:
5ACD 8.1, " Receiving Process"
5ACD 8.2, " Material Control"
PINGP Section Work Instruction,' (SWI's):
SWI-SQE-12, " Quality Contrcl Receipt Inspection"
The overall procurement process is governed by procedure N1ACD 6.1, " Uniform
Nuclear Procurement Process." This procedure, defines the licensee's Quality
Level A or B procurement, the quality level depending on the method of
procurement and the intended use or availability for use of the item or service
purchased.
Quality Level A and B procurement each have associated prescribed controls,
commensurate with the degree and nature of importance to plant safety of the
purchased system or equipment. To determine the proper level of control and
quality assurance required for procurement, as well as for other reasons, the
type and relative degree of importance to safety are defined for all plant
systems and equipment in accordance with the guidelines in the applicable
industry standards.
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Those materials, equipment, and services considered not important to safety are
procured under Quality Level B (covered by procedure N1AWI 6.1.10).
Under the licensee's program for equipment environmental qualification (EQ)
pursuant to 10 CFR 50.49, additional electrical equipment which is not func-
tionally classified 1E, but which is required to be environmentally qualified
(including certain non-1E and post-accident monitoring equipment), is treated
for procurement purposes, as Class 1E equipment.
Procedure N1ACD 6.1 prescribes certain controls for each procurement quality
level. For procurement classified as QA1, the procedure states that 10 CFR
Part 21 applies. QA1 is to be reserved for purchases of safety-related
equipment, components, and services, and suppliers are to be approved, that is,
included on the Approved Suppliers List (ASL). The procedure provide < for
three methods of or " approaches to" achieving quality: (1) use of " approved
suppliers" who have a complete 10 CFR Part 50 Appendix B QA program and accept
orders to which 10 CFR Part 21 is applicable (covered by procedure N1AWI
6.1.7), (2) use of " verified suppliers" whose QA program is acceptable when
supplemented by source verification and surveillance activities, but may not be
complete with respect to 10 CFR Part 50 Ap
6.1.8), and commercial grade procurement covered (pendix B (covered
by N1AWI by procedure
6.1.9), and (3) use N1AWI
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of " commercial grade suppliers" supplemented by a dedication process to assure i
that the procured item will function properly in a safety-related application.
Review of the procedures revealed some programmatic deficiencies and review of
individual Quality Level A procurement identified many instances in which
these practices resulted in parts of indeterminate quality being installed in
safety-related systems. Examples of these are discussed in the main body of
this inspection report.
The elements missing in the licensee's program that would be necessary for
adequate dedication would include, but are not limited to: (1) establishing
traceability of the component to its original manufacturer; (2) definition of
the safety functions of the item to be dedicated and the conditions under which
they must be performed; (3) identification of critical characteristics or
attributes considered vital to the item's ability to perform as required under
all design conditions including seismic; (4) review and technical evaluation
of any changes in design, process, and materials and of any effect on the
suitability for nuclear applications under all design conditions; (5) methods
for receipt inspection and testing sufficient to demonstrate that specifica-
tionsaremet;and(6)detailedrequirementsfordocumentationofthese
ections.
First, in implementation of the dedication program, the licensee failed in most
cases to establish traceability. Although many non-approved or non-verified
vendors provided C0C's, the licensee accepted them without substantiating the l
validity or basis of the C00, or verifying the vendors' ability to make such J
certifications. This was particularly relevant in the cases of vendors who are !
not the original manufacturer. The programmatic problem is that this practice l
is allowed by the procedures and that such verification of C0C's is not )
explicitly called for in the procedures.
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Second, the procedures require that the licensee evaluate the suitability of l
commercial grade items for.use in safety-related applications. This consists
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of nothing more than a verification that the item in question meets the
definition of commercial grade as given in 10 CFR Part 21. ,
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In practice, no further engineering or technical evaluation, and no review of
form, fit, and function beyond part number verification and catalog specifica- >
tions are documented. Therefore, under this system, the process of dedicating !
or upgrading the commercial grade material for nuclear safety service at PINGP
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lacks crucial elements. As a result, the process fails to provide the
assurances otherwise associated with manufacturing under a 10 CFR Part 50,
. Appendix B QA program, that is audited and approved by the licensee, and the
assurance, under 10 CFR Part 21, that any deviations from technical procurement
specifications would, as a minimum, be reported to the licensee for evaluation
of the potential for creation of a substantial safety hazard.
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It should be noted that the licensee has revised their procurement process and ,
procedures for commercial grade procurement. Procedure N1AW1 6.1.9 was in a i
preliminary stage and had not-been approved by the appropriate levels of l
management for everyday use. The licensee stated that this revision to NIAWI j
6.1.9 addresses the inspectors' concerns documented above. The inspecturs did
not review this revision as part of the inspection.
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