ML20244B566

Notice of Violation from Insp on 880523-0722.Violations Noted:Numerous commercial-grade Items Installed in safety-related Sys W/O Documenting Suitability & Procurement Documents Did Not Specify 10CFR21 Applicability

ML20244B566
Person / Time
Site:	Maine Yankee
Issue date:	06/07/1989
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20244B562	List: IR 05000309/1988200 ML20244B566
References
50-309-88-200, EA-89-043, EA-89-43, NUDOCS 8906130173
Download: ML20244B566 (40)

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APPENDIX A NOTICE OF VIOLATION Mai.e Yankee Atomic Power Company Ma,ne Yankee Atomic Power Plant Docket No.: 50-309 License No.. DPR-36 EA No.: 89-43 During May 23 through 27, June 6 through 10, and July 18 through 22, 1988, representatives of the NRC Vendor Inspection Branch reviewed the vendor interface and procurement programs of the Maine Yankee Atomic Power Plant (MYAPP). As a result of that inspection, and in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Action," 10 CFR 2, Appendix C (1988), the following violations were identified:

1.

10 CFR 50, Appendix B, Criterion XVII requires, in part, that sufficient records be maintained to furnish evidence of activities affecting quality.

These records shall include the results of reviews, inspections and material analysis. Criterion VII requires, in part, that maasures be established to assure that purchased material and equipment tunform to procurement documents. The measures shall include provisions, as appropriate, for source evaluation and selection, and objective evidence of quality of purchased material. Criterion III requires, in part, that measures be established for the selection and review for suitability of application of materials, parts, and equipment that are used in safety related structures, systems and components.

The Maine Yankee Operational Quality Assurance Program,Section II, commits to ANSI N45.2.13-1976, " Quality Assurance Requiren nts for the Control ANSI fo Procurement of Items and Services for Nuclear Puter N 45.2.13-1976, Plants."

Section 10.2, states that, when certificates of compliance are used to provide documentary evidence that items conform to procurement documents, means shall be established to verify the validity of supplier certificates and the effectiveness of the certification system, such as the performance of audits of the supplier or independent inspection or test of the purchased items.

Contrary to the above, as of July 22, 1988, Maine Yankee Atomic Power {

Plant installed numerous commercial grade items into safety related systems without adequately documenting their suitability for safety related applications in that records did not include the results of l j

reviews, inspections, tests or material analysis nor was there source i evaluation and selection or other objective evidence of quality of the purchased material which would validate the suitability of the material.

In addition, Maine Yankee Atomic Power Plant accepted certificates of compliance for purchased material from vendors without verifying the validity of the supplier certificates or the effectiveness of certification system.

OFFICIAL RECORD COPY IR MY 88-200 - 0004.0.0 04/03/89 8906130173 890607 PDR ADOCK 05000309 a PDC

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APPENDIX A 1

a. The following are four examples of commercial grade purchase orders which lack adequate documentation of suitability for. safety related applications. Twenty-six other examples are documented in NRC Inspection Report No. 50-309/88-200.

1. P0 40755 - Replacement parts for four 125 volt vital bus invertors

2. PO 42968 - Commercial grade BFD 44 and BFD 80 relays from Westinghouse Electric Supply Company (WESCo) installed in the main control board

3. PO 44737 - Preferred Engineering' for Reactor Vessel Stud Hole Plugs

4. PO 48351 - Gilman Electric for Westinghouse Circuit Breakers

b. The following are four examples.of purchase orders whose material was accepted for safety related applications based on certificates of compliance without verifying the validity of the supplier certificates or the effectiveness of the certification system. Six other examples are documented in NRC Inspection Report No. 50-309/88-200.

1. P0 48520 - Nutherm for Westinghouse HCB 2400 Circuit Breakers

2. P0 43032 - Solidstate Controls for Inverter

3. P0 43582 - Versatile Measuring for Alarm Indicator

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4. PO 44407 - Westinghouse Coils for 480 Volt Contractors This is a Severity Level IV Violation (Supplement 1).

2. 10 CFR 21, Paragraph 21.31 states that.each NRC licensee shall assure that each procurement document for a facility, or.a basic component issued by it on or after January 6,1978 specifies that the provisions of 10 CFR Part 21 apply. t s

Contrary to the above as of July 22, 1988, numerous procurement documents  !

for procurement level 1 (safety related) material, which was purchased.

after January 6,1978, did not specify the applicability of 10 CFR 21. The following are four examples of such procurement documents. Thirteen 1 additional examples are documented in NRC Inspection Report No. I 50-309/88-200.

1. PO 42784 - Quality assurance related safety class purchase of test equipment, avubleshooting and calibration services 1

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0FFICIAL RECORD COPY IR MY 88-200 - 0004.0.1 04/03/89 l

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APPENDIX A 2. P0 45025 - Purchase of Safety Class 1E Replacement Station Batteries-

3. P0 47714 - Satin American Co. for GE EC-1 Overcurrent Trip Devices for Breaker EZPB in MCC BA and 88

4. PO 41352 - Henry Pratt for 24-inch Butterfly Valves in the Service Water System This is a Severity Level V Violation (Supplement No.1).

3, 10 CFR Part 50, Appendix B, Criterion XVI, requires that measures be established to assureJthat conditions adverse to quality, such as failures, defective. material and equipment, and nonconformances are promptly identified and corrected. 'In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to. appropriate levels of management.

Maine Yankee Procedure 20-2-1, Operational Assessment System, requires that information from outside vendors be entered into, tracked by, evaluated by, and reported to appropriate levels of senior management.

Contrary to the above, as of May 23, 1988, conditions adverse to quality reported by an outside vendor were not promptly corrected nor were corrective actions documented in that 98 of199 Power Pointers and Maintenance Instructions from the emergency diesel generator vendor, General Motors / Electro-Motive Division (GM/EMD) were never entered into the Operational Assessment System for a documented review for their applicability to the MYAPP; nor was the vendor-information tracked by, evaluated by, or reported to appropriate levels of senior management.as required by the Operational Assessment Systems. Therefore, many recom-mended corrective actions had not been implemented. Many GM/EMD recommendations had not been acted on and the diesel vendor manual was not up to date.

This is a severity Level V Violation (Supplement No 1.) No response to this violation is required.

Pursuant to the provisions of 10 CFR 2.201, Maine Yankee Atomic Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region I,-and a copy to the NRC Senior Resident Inspector within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an OFFICIAL RECORD COPY IR MY 88-200 - 0004.0.2 04/03/89

r APPENDIX A order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action'as.may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. ,

FOR THE NUCLEAR REGULATORY COMMISSION William V. Johnston, Acting Director Division of Reactor Safety.

Dated at King of Prussia, Pennsylvania this day of June 1989 j

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0FFICIAL RECORD COPY IR MY 88-200 - 0004.0.3  !

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ENCLOSURE 2 Enforcement Conference Meeting Summary I

1.0 Introduction On March 29, 1989, an Enforcement Conference was held in NRC Region I between NRC staff and Maine Yankee representatives to discuss apparent violations of NRC requirements in the use of commercial grade components i

in safety related applications without proper dedication. The violations included the lack of engineering support documentation to assure proper dedication of commercial grade items used in safety related applications; .

the acceptance of certificates of compliance from unapproved vendors  !

without proper validation; and the failure to invoke the provisions of 10 CFR Part 21 on some. safety related purchase orders. Although subsequent licensee reviews indicated that there were no safety issues ider,tified in.

the use of these components, the enforcement conference was held to ,

discuss the licensees apparent lack of controls in the procurement process.

In addition, the licensee's reevaluations program to' support their position that "no safety concerns" and the licensees corrective actions both planned and implemented to prevent similar problems in the future were also discussed.

2. Meeting Presentation and Discussion:

The NRC representatives presented the findings of inspection report-No.

50-309/88-200 including the details of the potential enforcement findings.

The licensee described the methods used and the results obtained.from their analysis of the potential enforcement findings. A copy of this presentation is included as Enclosure (3) to the cover letter. The licensee's presentation and subsequent discussion addressed the following:

Analysis and inspection was done by both the licensee and consulting engineers of procurement level 1 and procurement level 2 purchase orders issued from 1983 to 1988. The items from the 550 procurement  ;

level 2 purchase orders -that were used in safety related applications .

were verified to be equal to or better than the original design equipment, parts or materials 'j' An assessment of the results of not invoking the requirements of >

10 CFR Part 21 on procurement level 1 purchase orders and the use of certificates of compliance from vendors not on their approved vendors j list was determined not to present a safety concern. '

Enclosure 2 -

A reevaluation of the 99 Power Pointers and Maintenance Instructions from their emergency diesel generator vendor, General Motors /

Electromotive Division (GM/EMD) by the licensee reportedly did'not change their original disposition. The decision not to enter the Power Pointers into the Operational Assessment System (OAS) was a management decision; however, the licensee stated that they had changed this practice.

During each refueling, instruments that are in place are used to -

measure RCS flow from which flow is calculated and recorded. The setpoint for the low flow trip. is then set at 93 percent of nominal.

flow. This results in a trip setpoint that is approximately seven percent above the limiting safety system setpoint requirement.

Since 1972, the recorded flow using the Steam Generator DP data, has been above 385,000 gpm. Technical Specification (TS) paragraph 3.10.2 requires "a nominal valve of 360,000 gpm during steady, state-I operation whenever the reactor is critical." The four RCS total.

flow channels.are recorded and logged on each shift. Thus, the requirements of technical specifications are met.

The license presented details of corrective actions already taken to assure that their plant was operating in a safe condition and long. term controls to assure that they maintain these in a safe condition.

3.0 Conclusions The NRC determined that the lack of sufficient records to support their.

engineering evaluations of commercial grade components, accepting certificates of compliance from vendors not on their approved vendors list and not invoking the requirements of-10 CFR Part 21 on' procurement level 1 (PL-1) purchase orders are violations of 10 CFR 50 Appendix B and 10 CFR

21. The licensee's reevaluation program verified that the parts and materials purchased were equal to or better than their original designed parts and material and no safety concern exist. An NRC inspection on Februa"y 28 - March 3, 1989 (50-309/89-03) verified, for those samples reviewed, that the licensee's reevaluation program did not identify any safe cy concerns with their purchased parts and materials. The licensee's long term corrective measures will-be reviewed during future safety inspections.

In addition, the NRC determined that the failure to review Power Pointers properly or to enter them in your Operational Assessment System was a violation of NRC requirements. However, inspection No. 50-309/89-03 determined the licensee had taken appropriate corrective actions.

Therefore, no further corrective action would be required.

The licensee's method of complying with their Technical Specification (TS) 3.10.2 concerning reactor coolant system flow was considered not to be a TS violation. The licensee method for complying with their TS 3.10.2 l was reviewed by NRC, Reactor System Branch and determined to be acceptable. No further action is required concerning this item.

Enclosure 2 4.D Meeting Attendees:

Nuclear Regulatory Commission R.' Gallo, Chief, Operations Branch, Division of Reactor Safety (DRS);

N. Blumberg, Chief,' Operational Programs Section, Operations Branch, DRS E. Brach, Chief, Vendor Inspection Branch, NRR/VIB A. Finkel', Senior Reactor Engineer, Operational Program Section, DRS R. Freudenberger, . Resident Inspector, Sec' tion 3, Projects Branch 3, Division of Reactor Projects (DRP)

J. Gutierrez, Regional Counsel t

C. Holden, Senior Resident Inspector,-Section 3, Projects Branch 3, DRP.

D. Holody, Jr. , Enforcement Officer W. Johnston, Deputy Director, DRS W. Kane, Director, DRP D. Limroth, Project Engineer, Section 3, Projects Branch 3, DRP J. Luehman, Senior Engineer Specialist, Office of Enforcement T. Martin, Director, DRS R. McIntyre, Senior Reactor Engineer, NRR/VIB P. Sears, Maine Yankee Project Manager, PDI-3/NRR C. Seeling, Program Analyst, NMSS/HQ L. Tripp, Chief, Section 3, Projects Branch 3, DRP J. Wiggins, Chief, Project Branch 3, DRP P. Wilson, Reactor Engineer Section 3, Projects Branch 3. DRP Maine Yankee Atomic Power Company and Consultants t l

W. Craig, Vice President, Cygna Energy Services G. Fehr, Manager, Management Services, Cygna Energy Services C. Frizzle, President, Maine Yankee Atomic Power. Company J. Garrity, Vice President Engineering and Licensing J. Heroert, Manager, Plant Engineering S. Nichols, Licensing Supervisor M. Philips, Attorney, Biship and Look D. Whittier, Manager, Nuclear Engineering and Licensing l

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ENCLOSURE (3) Page 1 of 33 OUTLINE MYAPC0 - NRC ENFORCEMENT CONFERENCE NRC INSPECTION REPORT NO. 50-309/88-200 MARCH 29, 1989 I. INTRODUCTORY REMARKS - C. D. FRIZZLE II. BACKGROUND - J. H. GARRITY III. POTENTIAL ENFORCEMENT FINDINGS - J. H. GARRITY/G. D. WHITTIER A. PEF 50-309/88-200-01 (JHG)

1. PL2 PURCHASES / DEDICATION PROCESS

2. PART 21 REQUIREMENTS

3. VALIDATION OF CERTIFICATES OF CONFORMANCE FROM NON-AVL VENDORS B. PEF 50-309/88-200-02 (GM/EMD POWER POINTERS AND MAINTENANCE INSTRUCTIONS) (GDW) b C. PEF 50-309/88-200-03 (RCS FLOW UNCERTAINTIES)

IV.

SUMMARY

- J. H. GARRITY V. CONCLUDING REMARKS - C. D. FRIZZLE l

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.. . ENCLOSURE-(3): Page 2 of 33

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C. D.-FRIZZLE INTRODUCTORY. REMARKS i

o ASSURANCE OF QUALITY IS FUNDAMENTAL TO THE PHILOSOPHY AT MAINE YANKEE -l PLANT (MYP) o THIS HAS RESULTED IN 16 YEARS OF SAFE OPERATION AT MYP o PROCUREMENT PRACTICES ARE IMPORTANT TO SAFE OPERATION AND MYP TAKES 4 SERIOUSLY THE INSPECTIONS' FINDINGS

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o BASED ON OUR REVIEH THE FINDINGS DO NOT RAISE HARDWARE SAFETY ISSUES- )

o NRC REQUIREMENTS IN THE PROCUREMENT AREA ARE EVOLVING o MYAPC0 HAS TAKEN PROMPT AND COMPREHENSIVE' ACTIONS TO ADDRESS STAFF CONCERNS )

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ENCLOSURE (3)- Page 3 of_33

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l PARTIAL LISTING OF MYAPC0 ACTIONS IN RESPONSE TO STAFF CONCERNS

'l o REASSESSMENT OF THE CRITERIA FOR PROCUREMENT LEVEL 1 PURCHASES ,

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o REVISIONS TO PROCEDURES IMPLEMENTING 10 C.F.R. PART 21 o ADOPTION OF EPRI GUIDELINES FOR USE OF COMMERCIAL GRADE ITEMS (EPRI NP-5652) o A COMPREHENSIVE REVIEW OF PROCUREMENT LEVEL 2 (PL2) PURCHASES FOR THE LAST FIVE YEARS TO ENSURE " EQUAL-TO-OR-BETTER-THAN" o A REVIEW TO IDENTIFY ANY EQUIPMENT FAILURE ASSOCIATED WITH PL2 PURCHASES o EVALUATION OF NRC'S SPECIFIC CONCERNS WITH THE 55 P.O.'S IDENTIFIED (JUNE 10, .1988 MEETING) i

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J. H.'GARRITY.

l-BACKGROUND-o MYP DESIGNED AND RECEIVED CP (19 ) PRIOR TO ISSUANCE OF APPENDIX B IN 1970 1 c MYP REACTOR VESSEL. STEAM GENERATORS, PRESSURIZER, AND RCP'S HERE DESIGNED AND FABRICATED TO ASME CODE SECTION III o REACTOR COOLANT LOOP PIPING AND FITTINGS DESIGNED AND FABRICATED TO )

ANSI B31.1 o REMAINDER OF PLANT HAS BASICALLY COMMERCIAL GRADE o THE MAINE YANKEE QUALITY ASSURANCE PROGRAM (NYQAP) ENDORSES ANSI NI8.7 HHICH PROVIDES:

" PROCEDURES SHALL BE ESTABLISHED AND IMPLEMENTED TO ENSURE THAT PURCHASED MATERIALS AND COMPONENTS ASSOCIATED HITH SAFETY-RELATED STRUCTURES OR SYSTEMS ARE:

~) l (1) PURCHASED TO SPECIFICATIONS AND CODES i EQUIVALENT TO THOSE SPECIFIED FOR THE ORIGINAL '

EQUIPMENT OR THOSE SPECIFIED BY PROPERLY REVIEHED j AND APPROVED REVISION. (IN THOSE CASES HHERE THE ORIGINAL ITEM OR PART IS FOUND TO BE COMMERCIALLY .,

"0FF THE SHELF," OR WITHOUT SPECIFICALLY IDENTIFIED QUALITY ASSURANCE REQUIREMENTS, SPARE AND REPLACEMENT PARTS MAY BE SIMILARLY PROCURED  !

BUT CARE SHALL BE EXERCISED TO ASSURE AT LEAST -

EQUIVALENT PERFORMANCE....)"  !

o CONSISTENT WITH INTENT OF APPENDIX B AS NOTED IN THE STATEMENT OF CONSIDERATION:

"THE QUALITY ASSURANCE REQUIREMENTS ESTABLISHED-BY THESE CRITERIA ARE INTENDED TO ASSURE THAT:

(d) SUCCEEDING ACTIVITIES SUCH AS OPERATING, ,

TESTING, REFUELING, REPAIRING, MAINTAINING, AND )

MODIFYING NUCLEAR POWER PLANTS, ARE CONDUCTED IN ACCORDANCE WITH QUALITY ASSURANCE PRACTICES CONSISTENT WITH THOSE EMPLOYED DURING DESIGN AND CONSTRUCTION."

o MYQAP HAS REVIEHED AND ACCEPTED BY THE NRC STAFF o MYQAP AUDITED BY NRC STAFF HITHOUT SIGNIFICANT ADVERSE FINDINGS SLIDE 4 j

,. ENCLOSURE (3) Page 5 of 33

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BACKGROUND o PART 21 IS NOT A MODEL OF CLARITY. AS NUREG -0302 STATES:

"IT HAS A DIFFICULT RU! E TO HRITE - PARTS OF IT INCLUDE WORDS SUCH AS REASONABLY INDICATING, RESPONSIBLE OFFICER, COULD CREATE A SUBSTANTIAL SAFETY' HAZARD; ETC. ANY TIME ONE HAS TO APPLY THESE KINDS OF HORDS TO A SPECIFIC HORK ACTION, REASONABLE MEN WILL DIFFER IN.THEIR UNDERSTANDINGS OF PRECISELY WHAT.THE H0RDS MEAN." [ REMARKS BY G. H. REINMUTH, OIE, 1977]

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ENCLOSURE (3) Page 6 of 33-

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NRC POTENTIAL ENFORCEMENT FINDINGS ,

A. PEF 50-309/88-200-01 (THREE FINDINGS) o "THE' APPARENT USE OF PL2 PURCHASES OF COMMERCIAL GRADE REPLACEMENT' ITEMS IN SAFETY-RELATED APPLICATIONS HITH0VT AN APPROPRIATELY DOCUMENTED EVALUATION OR DEDICATION PROCESS."

o "THE APPARENT FAILURE TO IMPOSE ON VENDORS THE PROVISIONS OF 10' j C.F.R. PART 21 HHEN THE PURCHASE ORDERS SPECIFY REQUIREMENTS TO l

NUCLEAR SPECIFICATIONS." l o "THE APPARENT FAILURE TO VALIDATE CERTIFICATES OF CONFORMANCE (C0C)

RECEIVED AND ACCEPTED FROM VENDORS NOT ON THE APPROVED VENDOR'S LIST."

B. PEF 50-309/88-200-02 o "THE APPARENT FAILURE TO ENTER GM/EMD P0HER POINTERS AND MAINTENANCE INSTRUCTIONS FOR THE EMEF.GENCY DIESEL GENERATORS INTO THE OPERATIONAL i ASSESSMENT SYSTEM FOR REVIEH OF APPLICABILITY. THEREFORE MANY GM/EMD l RECOMMENDATIONS HAD NOT BEEN ACTED ON AND THE VENDOR MANUAL HAS NOT

} UP TO DATE."

C. PEF 50-309/88-200-03 o " CONTRARY TO TECHNICAL SPECIFICATIONS, MYAPCO PERFORMS NO EVALUATION DURING PLANT OPERATIONS TO ENSURE THAT THE CALCULATED RCS FLOW RATE  ;

(MINUS A LOH BOUND UNCERTAINTY) IS CONSISTENTLY HITHIN THE LCO VALUE  !

0F 360,000 GPM."

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.. ENCLOSURE'(3) .Page 7 of 33

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POTENTIAL ENFORCEMENT FINDING 01 III.A SUB-ISSUE 1 (PL2 PURCHASES / DEDICATION PROCESS)

"THE APPARENT USE OF PL2 PURCHASES OF COMMERCIAL GRADE REPLACEMENT' ITEMS IN SAFETY-RELATED APPLICATIONS WITHOUT AN APPROPRIATELY DOCUMENTED EVALUATION OR DEDICATION PROCESS."

A. MYAPC0 POSITION ON EXISTENCE OF VIOLATION WHILE MYAPC0 AGREES THAT ITS DOCUMENTATION OF ITS EVALUATION AND DEDICATION PROCESS FOR COMMERCIAL GRADE PROCUREMENT COULD HAVE BEEN (AND N0H IS) HUCH STRONGER, NE DO NOT BELIEVE THAT A VIOLATION OF NRC REQUIREMENTS HAS OCCURRED.

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. ENCLOSURE (3) Page 8 of 33

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B. DISCUSSION OF MYAPCO POSITION:

1. SCOPE OF CG PROCUREMENT OF CONCERN:

o NO E ENVIRONMENT COMPONENTS o NO$SSSCOMPONENTS o SEISMIC REQUIREMENTS VERIFIED BY DIFFERENT PROGRAM \

o LIMITED NUMBERS OF COMPONENTS INVOLVED, E.G. FROM ABOUT \

1983-1988 ONLY ABOUT 550 PROCUREMENT OF COMMERCIAL GRADE FOR SAFETY APPLICATION

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o COMPONENTS INCLUDED NOTED IN PIE CHART l

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'} (PL2 PURCHASED / DEDICATION PROCESS)

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_ENCLOSUREE(3)- Page 9Lof 33:

9. CATEGORIES-OF 543 P.O.'S i

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1 l CANCELLED FITTINGS RETURNED .g~

13% NNS' l Igg.g 7% 4g PACKING l GASKETS 8%

13% )

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l OTHER = 551 1 L i 296 PO'S l

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ENCLOSURE (3) Page 10 of 33 NRC NOTE:

Slide 10 not presented by licensee l

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. ENCLOSURE (3) Page .11 of 33  !

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2. DOCUMENTATION OF PROCESS 1

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o . AGREE WITH STAFF -- DOCUMENTATION COULD BE STRENGTHENED o H0HEVER, DOCUMENTATION REFLECTS THE PROCESS HAS COMPLETED, AND EQUAL

, TO OR BETTER THAN REPLACEMENTS PROCURED -- FINDINGS MADE BY QUALIFIED l EN,GINEERS AND OUR REVIEW (DISCUSSED BELOH) DEMONSTRATES THAT THE l FINDINGS HERE CORRECT. l o LACK OF MORE COMPLETE DOCUMENTATION A RESULT OF EVOLUTION OF ISSUE:

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- NO FIRM GUIDANCE NO FIRM REQUIREMENTS

- RECENTLY RELEASED GENERIC LETTER

- AN ADVANCED NOTICE OF PROPOSED RULE-MAKING HAS RECENTLY PUBLISHED

• HHILE DOCUMENTATION COULD HAVE BEEN AND HAS BEEN STRENGTHENED, NO

} VIOLATION OCCURRED c, '

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}- (PL2 PURCHASES / DOCUMENTATION PROCESS)

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ENCLOSURE (3) .Page 12 of 33

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3. ADE00ACY OF EVALUATION / DEDICATION PROCESS 1 o TO. EVALUATE, HAD AN OUTSIDE REVIEW OF PROCESS 1

o REVIEW COVERED 100% OF PL-2 PROCUREMENT FOR A 5 YEAR PERIOD RANGING FROM ABOUT 1983-1988 4

o BOTTOM LINE HAS THAT OUR PROCESS TO ASSURE EQUAL TO CR BETTER THAN REPLACEMENTS WAS ADEQUATE -- NO SAFETY PROBLEMS o CYGNA HILL DESCRIBE REVIEW T SLIDE 12 J (PL2 PURCHASES / DEDICATION PROCESS)

, ^',,[!jCLOSURE(3) Page 13 of 33 NEXT

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• DOCUMENT AS COMPLETE, GO TO NEXT I PUFICHASE ORDER REVIEW PROCESS wo PL-27 PROCUREMENT LEVEL 27 YES 5i NO SAFETY RELATEO?

g PLANT? USED IN PLANT?

YES NO N

LIKE FCR N ENC. EVAL OF LIKE? p[VIATIONS LIKE-FOR-LIKC REPLACEMENT?

I LEE A YES

• LIKE A "LEAO ITEM"?

LEAD ITEM 7 NO O NAME CRITICAL CHARACTER:STICS .

FOR ACCEPTANCE O DOCUMENT I WERE CC"s YES

• WERE Cit!TICAL CHARACTERISTICS VERirlED VERIFIED IN RECEIPT INSPECTION?

1N RL7 NO O SEARCH AVAILABLE INFORMATION FOR PROOF OF JNSPECTION OR SATISFACTION OF CC's

\ CRITICAL CHARACTER!STICS OK, YES

• DY EXISTING DOCUMENT ATION EVEN BY EXISTINO THOVOH NOT CHECKED DOCUMENTATION IN RECEPT INSPECTION?

NO O SAMPLE PARTS ANO REINSPECT FOR CR:TICAL CHARACTERISTICS O CHECK MPs / POST TEST YES

• CC's OK7, tOCcE m0 esESS SLIDE 13

ENCLOSURE {3) Page 14 of 33

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4.

SUMMARY

O REVIEW 1

.j o .~ REVIEW IN ESSENCE, CONFIRMED MYAPCO'S DEDICATIONS USING IN GENERAL q THE EPRI GUIDELINES o THE P.ESULTS SH0HED:

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- HHAT HAS ORDERED HAS RECEIVED REPLACEMENTS HERE EQUAL TO OR BETTER THAN ORIGINAL j 1

IN ALL CASES THE PLANT HAS SAFE -i b

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ENCLOSURE (3) Page 15 of 33

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C. SAFETY SIGNIFICANCE o THIS POTENTIAL ENFORCEMENT FINDING DOES NOT PRESENT A SAFETY CONCERN o THIS FINDING RELATES TO:

A LIMITED NUMBER OF PURCHASES 00 EQ COMPONENTS NO NSSS COMPONENTS NO SEISMIC CONCERNS o BASED UPON MYP'S COMPREHENSIVE (10D%) FIVE-YEAR PL2 REVIEH:

NO ADVERSE SAFETY SIGNIFICANCE NO REQUIRED HARDWARE REPLACEMENTS COMPONENTS SUITABLE FOR APPLICATION IN SAFETY CLASS SYSTEMS o ACCORDINGLY, HHILE HE BELIEVE NO ENFORCEMENT ACTION IS HARRANTED, IF

]) THE STAFF DISAGREES THEN BECAUSE OF LACK OF SAFETY SIGNIFICANCE l

ENFORCEMENT SHOULD NOT BE ESCALATED.

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, ENCLOSURE (3) . Pa9e 16 of.33.

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) l D. OTHER CONSIDERATIONS l

i' o IF THE STAFF BELIEVES ESCALATED ENFORCEMENT ACTION SHOULD BE-IMPOSED, PROMPT AND EXTENSIVE ACTIONS IN RESPONSE TO CONCERNS HARRAuT FULL MITIGATION, ACTIONS INCLUDE:

MYAPCO HAS'TAKEN PROMPT CORRECTIVE ACTION TO DEVELOP A NEW COMMERCIAL-GRADE PROCUREMEN

T. PROCEDURE

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- MORE GENERALLY, NYAPCO HAS IMPLEMENTED THE COMPREHENSIVE ACTIONS IDENTIFIED IN THE JULY 12, AUGUST 10, AND NOVEMBER 8 '1988 1 SUBMITTALS TO ADDRESS NRC CONCERNS IN THIS AREA. THESE ARE: i o REASSESSMENT OF THE CRITERIA FOR PROCUREMENT LEVEL 1 PURCHASES o REVISIONS TO PROCEDURES IMPLEMENTING 10 C.F.R. PART 21 o ADOPTION OF EPRI GUIDELINES FOR USE OF COMMERCIAL GRADE ITEMS (EPRI NP-5652) .

) o A COMPREHENSIVE REVIEW 0F PROCUREMENT LEVEL 2 (PL2)'

PURCHASES FOR THE LAST 5 YEARS'TO ENSURE i

" EQUAL-TO-OR-BETTER-THAN."

k o A REVIEH TO IDENTIFY ANY EQUIPMENT FAILURE ASSOCIATED WITH i PL2 PURCHASES o EVALUATION OF NRC'S SPECIFIC CONCERNS WITH THE 55 P.O.'S IDENTIFIED'(JUNE 10, 1988 MEETING)

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SLIDE 16

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. ENCLOSURE (3) Page 17 of 33

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POTENTIAL ENFORCEMENT FINDING 01 III.B SUB-ISSUE 2 (PART 21 REQUIREMENTS)

"THE APPARENT FAILURE TO IMPOSE ON VENDORS THE PROVISIONS OF 10 C.F.R.

PART 21 HHEN THE PURCHASE ORDERS SPECIFY REQUIREMENTS TO NUCLEAR SPECIFICATIONS."

A. MYAPCO POSITION ON EXISTENCE OF VIOLATION o HYAPC0 ADMITS THAT THERE HAVE BEEN A FEH INSTANCES OF PL1 PROCUREMENT FOR HHICH PROCUREMENT DOC'JMENTS DID NOT EXPLICITLY STATE THAT PART 21 APPLIED. H0HEVER, NYAPC0 SUBMITS THAT THE FINDING IS OF LITTLE SAFETY SIGNIFICANCE.

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} SLIDE 17 (PART 21)

-l ENCLOSURE (3) ~ Page 18 'of 33 ' j 1

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l B. DISCUSSION OF MYAPCO POSITION

1. OF 17 PROCUREMENT NOTED IN'THE' INSPECTION REPORT:

o 2 NERE ACTUALLY PL2 PROCUREMENT

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10 NERE PL1 ONLY BECAUSE OF OVERLY CONSERVATIVE MYAPCO PROCEDURES o S PL1 HITHOUT PART 21 DESIGNATED ,

2. IN SHORT, IN A FEH ISOLATED CASES VIOLATIONS EXISTED

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.) SLIDE 18 (PART 21)

ENCLOSUREi(3) . 'Page 19'of 33-ROOT CAUSE l'

o _ OVERLY CONSERVATIVE PROCUREMENT PRACTICES- . ,

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o LACK OF CLARITY IN'0UR PROCEDURES ON NHEN TO APPLY PART 21 >

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.)- SLIDE 19 (PART 21) L.j I

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, ENCLOSURE (3) Page_20 'of 33 j l

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j C. SAFETY SIGNIFICANCE-

'MYAPC0 MAINTAINS THAT THE FINDING IS OF LIMITED SAFETY SIGNIFICANCE AND DOES NOT HARRANT ESCALATED ENFORCEMENT ACTION BECAUSE:

- AS NOTED PREVIOUSLY, HE HAVE REVIEHED ALL OF THE PL1 ISSUES OF CONCERN AS LISTED IN THE IR HHERE PART 21 HAS NOT DESIGNATED IN THE PROCUREMENT DOCUMENT AND FOUND THAT ALL OF THESE PL1 PURCHASES INVOLVED AVL VENDORS HHERE THE APPLICABLE QA PROGRAM REQUIRES DIRECT REPORTING OF SAFETY DEFECTS.

- FURTHER, NE NOTE THAT FOR PROCUREMENT OF BASIC COMPONENTS, PART 21 ATTACHES WHETHER OR NOT IT IS DESIGNATED ON THE PROCUREMENT DOCUMENT.

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l' D. OTHER CONSIDERATIONS o IF THE STAFF FEELS THAT ESCALATED ENFORCEMENT ACTION IS NECESSARY, MYAPC0 SUBMITS THAT FULL MITIGATION IS APPROPRIATE FOR THE PROMPT AND 1 EXTENSIVE CORRECTIVE ACTIONS, NOTED ABOVE, AND THE FOLLOHING: i MYAPC0 HAS CHANGED ITS PROCEDURE (0-04-1) TO REQUIRE THAT PART 21 BE j IDENTIFIED AS APPLICABLE IN ALL PL1 PROCUREMENT

{

IN ADDITION, THE PROCEDURE PP,0VIDES SPECIFIC CRITERIA, CONSISTENT WITH THE DEFINITIONS SET FORTH IN 10 C.F.R. PART 21, T0 BE USED IN  !

CLASSIFICATION OF PROCUREMENT. j j

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ENCLOSURE'(3) Page.2I of 33  !

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POTENTIALEEFORCEMENT FINDING 01 III.C SUB-ISSUE 3 (VALIDATION OF COC'S FROM NON-AVL VENDORS)

"THE APPARENT FAILURE TO VALIDATE CERTIFICATES OF CONFORMANCE (COC) l REVIEHED AND ACCEPTED FROM VENDORS NOT ON THE APPROVED VENDORS LIST" l A. MYAPCO POSITION ON EXISTENCE OF A VIOLATION J

o MYAPCO AGREES THAT PROCUREMENT PRACTICES SHOULD INCLUDE ADEQUATE.

DOCUMENTATION OF ACCEPTANCE, BUT NEVERTHELESS DENIES THAT VIOLATION

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OF NRC. REQUIREMENTS HAS OCCURRED..

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ENCLOSURE (3) Page 22 of 33

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B. DISCUSSION OF THE HYAPC0 POSITION:

o AS PREVIOUSLY NOTED, HE CONDUCTED A 1001 REVIEH OF COMMERCIAL GRADE PROCUREMENT FOR A 5 YEAR PERIOD AND CONCLUDED THAT CUR DEDICATION PROCESS HORKS. HE ONLY PROCURED EQUAL-TO-OR-BETTER-THAN REPLACEMENT PARTS.

o ACCORDINGLY, HE HERE IN COMPLICANCE WITH NRC REGULATIONS REGARDING PROCUREMENT OF REPLACEMENT PARTS. THIS IS IN ESSENCE THE SAME BASE CONCERN EXPRESSED IN THE FIRST ASPECT OF THIS SAME FINDING (SUB-ISSUE 1 ABOVE) o THERE ARE A NUMBER OF OTHER HETHODS TO EVALUATE COC'S TO INCLUDE:

REPUTATION OF SUPPLIER PREVIOUS DEALINGS HITH SUPPLIER PERSONAL CONTACTS AND VISITS WITH SUPPLIERS TELEPHONE CONFERENCES HITH SUPPLIERS TO LEARN ABOUT THEIR COC PROCESS KN0HLEDGE OF VENDOR OPERATIONS AND/0R PERSONNEL COMMERCIAL GRADE SURVEY

) SLIDE 22 (VALIDATION OF COC'S)

. . ENCLOSURE (3) Page 23 of 33

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C. SAFETY SIGNIFICANCE o MYAPCO'S i. COMPREHENSIVE, 5-YEAR REVIEW OF P.O.'S (NOTED PREVIOUSLY)

INCLUDES PL2 PURCHASES FROM NON-AVL VENDORS. THIS REVIEW DEMONSTRATED:-

NO SAFETY SIGNIFICANCE-

- NO NEED FOR HARDWARE REPLACEMENTS o ACCORDINGLY, SHOULD THE NRC STAFF FIND VIOLATIONS ESCALATED ENFORCEMENT ACTION NOT HARRANTED.

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SLIDE 23 (VALIDATION OF C0Cs)

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, ENCLOSURE (3) Page 24 of'33 )

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D. OTHER CONSIDERATIONS -1 IN THE' EVENT THE STAFF CONSIDERS ESCALATED ENFORCEMENT ACTION, MYAPCO SUBMITS THAT ITS PROMPT AND EXTENSIVE ACTION IN RESPONSE TO STAFF CONCERNS HARRANT FULL MITIGATION.

o. MYAPCO HAS DEVELOPED A NEN COMMERCIAL GRADE PROCUREMENT PROCEDURE, 0-04-4 NHICH UTILIZES EPRI GUIDANCE ON VALIDATION OF COCS.

o THESE NEN PROCEDURES REQUIRE IMPROVED DOCUMENTATION OF OUR VALIDATION PROCESS o OTHER ACTIONS, NOTED ABOVE.

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. ENCLOSURE (3) Page 25 of 33 .

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i G. D. WHITTIER I

IV. POTENTIAL ENFORCEMENT FINDING 02 (GM/EMD POWER POINTERS)  ;

"THE APPARENT FAILURE TO ENTER GM/EMD POWER POINTERS AND ,

MAINTENANCE INSTRUCTIONS FOR THE EMERGENCY DIESEL GENERATORS INTO THE OPERATIONAL ASSESSMENT SYSTEM FOR REVIEW OF APPLICABILITY. . . . THEREFORE MANY GM/EMD RECOMMENDATIONS HAD NOT BEEN ACTED ON AND THE VENDOR MANUAL HAS NOT UP TO DATE."

A. MYAPCO POSITION ON EXISTENCE OF A VIOLATION:

o MYAPCO DENIES THAT IT FAILED TO CONSIDER THE GM/EMD P0klER POINTERS AND MAINTENANCE INSTRUCTIONS AND ACT ON THE GM/EMD RECOMMENDATIONS IN A TIMELY FASHION.

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ENCLOSURE.(3) Page 26 of 33-

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B. DISCUSSION OF MYAPCO POSITION:

o GM/EMD POWER POINTERS AND MAINTENANCE INSTRUCTIONS HERE NOT INCORPORATED INTO THE COMPUTERIZED OPERATIONAL ASSESSMENT SYSTEM (OAS) UNTIL 1988. H0HEVER,:IT DOES NOT FOLLON THAT MYAPCO DID NOT REVIEN THESE MATERIALS FOR APPLICABILITY AND TAKE APPROPRIATE ACTION. .

o SINCE 1977, GM/EMD POWER POINTERS AND MAINTENANCE INSTRUCTIONS HAVE BEEN SPECIFICALLY REVIEHED BY THE MYP MAINTENANCE MANAGER.

o AFTER REVIEHING EACH PONER POINTER THE MYP MAINTENANCE MANAGER-ACTED APPROPRIATELY ON THE GM/EMD RECOMMENDATION.

o A COMPREHENSIVE REASSESSMENT OF POWER POINTERS DATING BACK TO 1974 HAS BEEN COMPLETED, CONFIRMING THAT THE GM/EMD RECOMMENDATIONS HERE ADEQUATELY DISPOSITIONED.

o ACCORDINGLY, NYAPCO CONCLUDES THAT ITS PROCESS FOR REVIEHING THE APPLICABILITY OF THE POWER POINTERS HAS BEEN ADEQUATE AND THAT THERE HAS NO REGULATORY VIOLATION. NEVERTHELESS, SINCE MAY 1988

) HHEN THIS ISSUE HAS SELF-IDENTIFIED, THE APPLICABLE GM/EMD POWER-POINTERS HAVE BEEN INCORPORATED INTO THE OPERATIONAL ASSESSMENT

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,, ENCLOSURE-(3)~ Page 27 of 33 s

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C. SAFETY SIGNIFICANCE:

o MYAPCG t!LIEVES THAT GM/EMD POWER POINTERS AND MAINTENANCE i INSTRUCTIONS HAVE BEEN REVIEHED FOR APPLICABILITY TO THE MYP j EMERGENCY DIESEL GENERATORS.- NEITHER MYAPC0 NOR THE NRC HAS i

' IDENTIFIED ANY HARDWARE DEFICIENCY RELATED TO THIS POTENTIAL i ENFORCEMENT FINDING.

o THIS FINDING THEREFORE PRESENTS NO POTENTIAL OR ACTUAL SAFETY "

CONCERN.

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q ENCLOSURE (3) Page 28'of 33 1

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D. OTHER CONSIDERATIONS: a NHILE MYAPCO DOES NOT BELIEVE THIS PEF CONSTITUTES A VIOLATION, SHOULD THE NRC STAFF CONCLUDE OTHERWISE, MYAPC0 NOTES THAT: }-

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o. THIS SITUATION HAS SELF-IDENTIFIED o NO SAFETY CONCERNS HAVE ARISEN ,

o PROMPT AND EXTENSIVE REVIEW TO ASSURE NO SAFETY IMPACT o PROMPT ACTION TO INCORPORATE P0HER POINTERS INTO THE OAS o- ISSUE HAS NOT ASSOCIATED WITH ANY PREVIOUS VIOLATION j o ACCORDIt; GLY, PURSUANT TO THE-NRC ENFORCEMENT POLICY (SECTION V.G OF APP.C TO 10 CFR PART 2), ENFORCEMENT ACTION IS NOT HARRANTED '

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Page 29 of 33 j EHCLOSURE (3) r i

V. POTENTIAL ENFORCEMENT FINDING 03 (RCS FLOW RATE UNCERTAINTY)  !

" CONTRARY TO TECHNICAL SPECIFICATIONS, MYAPCO PERFORMS NO-EVALUATION DURING PLANT OPERATIONS TO ENSURE THAT THE-CALCULATED RCS FLOW RATE (MINUS A LONER BOUND UNCERTAINTY)

IS CONSISTENTLY HITHIN THE LCO VALUE OF 360,000 GPM."

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A. -MYAPCO POSITION ON EXISTENCE OF A VIOLATION: I o MYAPCO DENIES THAT IT FAILED TO MEET ANY APPLICABLE TECHNICAL SPECIFICATIONS REQUIREMENTS. .

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B. DISCUSSION OF HYAPCO POSITION:

o THE TECH SPEC LCO IS 360,000 GPM.

o SURVEILLANCE IS PERFORMED PER TECH SPEC:

i EACH SHIFT: COMPARISON OF TOTAL FLON INDICATIONS 1

REFUELING: -RPS CALIBRATION (FLOW TRIP)

MONTHLY: TEST TRIP BISTABLE o NO TECHNICAL SPECIFICATION HAS VIOLATED. --

o NOTE THAT RCS FLOW HAS BEEN VIRTUALLY CONSTANT OVER THE YEARe o

SUMMARY

OF RCS FLOW: -

ACTUAL FLOH (MIN.) 105.4%

(

) LCO FLON 100.0% (

PRETRIP ALARM (HIN.) 96.9%

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ACTUAL TRIP (MIN.) 95.3%

- TS TRIP 93.01 ASSUMED TRIP 91.0%- j 1

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ENCLOSURE (3) Page 31 of 33

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C. SUMMATION o NO TECHNICAL SPECIFICATION VIOLATION o N0 VIOLATION OF NRC REQUIREMENTS i

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SU.MMARY {

-1 A. PEF 88-200-01 (THREE FINDINGS) .)

1. INADEQUATE EVALUATION OR DEDICATION PROCESS REVIEW REFLECTS DEDICATION PROCESS HAS ADEQUATE -- .

NO SAFETY PROBLEMS

- WHILE DOCUMENTATION COULD BE STRENGTHENED, LITTLE GUIDANCE i ON HHAT IS NECESSARY -- EVOLVING GUIDANCE

- NO VIOLATION i

2. FAILURE TO IMPOSE PART.21

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ADMITS-TO FINDING IN CERTAIN RESPECTS

- ISOLATED FINDING 1

- SELF-IMPOSED, OVERLY-RESTRICTIVE PL2 PROCEDURES LACK OF CLARITY IN OUR PROCEDURES FOR APPLYING PART 21 NO SAFETY SIGNIFICANCE (PART 21 NAS APPLIED) d SEPARATE FROM THE OTHER TH0 FINDINGS IN THIS PROPOSED VIOLATION -- SHOULD NOT BE AGGREGATED

3. FAILURE TO VALIDATE COC'S

- RELATES TO " DEDICATION" PROCESS WHICH, AS NOTED ABOVE, HAS l PROVEN TO BE ADEQUATE NO SAFETY PROBLEM NO VIOLATION l

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,- ,. ENCLOSURE (3)_ Page 33 of 33 i .

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B. PEF 88-200-02:

ALLEGED FAILURE TO TAKE ACTION ON GM/EMD P0HER POINTERS AND MAINTENANCE INSTRUCTIONS FOR EDG POWER POINTERS AND MAINTENANCE INSTRUCTIONS HERE CONSIDERED AND.

AS APPROPRIATE, FULLY FACTORED INTO MYP OPERATIONS

- POWER POINTERS NOW INCORPORATED IN THE OAS NO VIOLATION C. PEF 88-200-03:

ALLEGED FAILURE TO COMPLY HITH TECHNICAL SPECIFICATIONS REGARDING RCS FLOW RATES l' -

DID COMPLY WITH ALL APPROPRIATE' TECH SPECS 1

- NO VIOLATION,

. ) D. SAFETY SIGNIFICANCE OF FINDINGS HERE MINIMAL. ACCORDINGLY, ESCALATED '

ACTION ENFORCEMENT ACTION NOT HARRANTED.

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E. IN ANY EVENT, EXTENSIVE AND PROMPT ACTIONS IN RESPONSE TO STAFF CONCERNS HARRANTS FULL MITIGATION OF ANY ESCALATED ACTION.

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) SLIDE 33 I

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