ML20245G194

Procurement Engineering Assessment Plan Final Rept

ML20245G194
Person / Time
Site:	Rancho Seco
Issue date:	02/28/1989
From:	Huebner R, Lawrence M, Peabody W SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20245G185	List: ML20245G181 ML20245G194
References
PROC-890228, NUDOCS 8906290049
Download: ML20245G194 (54)

Text

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l-i PROCUREMENT ENGINEERING ASSESSMENT PLAN FINAL REPORT FOR RANCHO SECO NUCLEAR GENERATING STATION SACRAMENTO MUNICIPAL UTILITY DISTRICT FEBRUARY 28, 1989

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M. Lawre c W. Peabody Project n ger /

Manager, Nuclear Engineering

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R. Huepnet "

_ a4D J.71nqqlst /

Manager, Nuclear Projects AGM, Quality a d Industrial Safety S. Yrunk" "

P. Be'tider Manager, Nuclear Licensing Manager,' Material Control

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/ B. Croley /

AGM, Technical Services i

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TABLE'OF' CONTENTS-l

-SECTION' DESCRIPTION EXECUTIVE

1.0 INTRODUCTION

2.0' -BACKGROUND.

-3. 0 SCOPE DESCRIPTION 4.0 PROCUREMENT PROJECT ELEMENTS 4.1 Random Survey of Commercial Grade Items.

'4. 2 Seismic Qualification of Commercial Grade Relays in the RPS and SFAS 4.3 Commercial Grade Items Installed in Environmentally Qualified Equipment 4.4' Enhancement of Existing Procedures and Training 4.5 Green Tag Program 4.6 Like-for-Like Commercial Grade Item ~

Dedication Evaluation (CGIDE)

Reverification

4. 7- RPS and Associated Components CGI Reverification.

4.8 10CFR21 Vendor Confirmation 4.9 Evaluation of Agastat Relays 4.10 Evaluation of Potentially Deficient I Fasteners 4.11 QA Surveillance

5.0 CONCLUSION

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6.0 REFERENCES

l ATTACHMENT 1 LISTING OF NCR/PDQs GENERATED DURING THE l

l PEAP  ;

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EXECDTIVE

SUMMARY

This report provides'the final results of the' Procurement Engineering Assessment Plan (PEAP) . This plan was originally established during December, 1987, when the CEO, Nuclear of the Sacramento Municipal Utility District (SMUD) directed the establishment of a Procurement Engineering Assessment Team with the objective to evnluate pact and current material control practices and to recommend potential improvements.

The PEAP was developed to describe'the objectives and specific methodology'related to assuring the acceptability of past procurement practices. The primary objective of the PEAP was to provide Rancho Seco. management with enhanced confidence that installed equipment meets design requirements. However, the initial review, known as Phase 1 of the plan, resulted in the identification of certain programmatic weaknesses. The PEAP was subsequently revised to address these and other concerns identified by SMUD and the NRC procurement team during their.

January 1988 inspection. Additional concerns centered on past practices involving commercial grade item procurement. The PEAP restart tasks, defined as Phase 2, were:

1. Random Survey of Commercial Grade Item (CGI) Parts.

2. Seismic Qualification of Commercial Grade Relays in the Reactor Protection System (RPS) and Safety Features Actuation System (SFAS).

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3. 25% Sample of Commercial Grade Items in Environmentally Qualified Equipment.

4. Enhancement of Existing Procedures / Training of Personnel.

5. Acceptability of Class I warehouse stock (Green Tag Program).

With the exception of Item 4 above, each issue was addressed by performing technical evaluations on a sample of selected components / parts installed ~or available for installation in Class I systems. These technical evaluations were conducted in accordance with detailed instructions. Issue 4 involved a comprehensive review and rewrite effort to enhance procurement-related procedures and the development of a procurement practices training program.

The interim results of the Project, as reported to the NRC in a report entitled " Procurement Engineering Assessment Plan Interim Report", dated March 1, 1988, concluded that there was a reasonable level of confidence that the safety function of installed equipment had not been adversely impacted by past procurement practices. Out of the approximately 1,300 parts reviewed at that time, only two EQ parts required replacement.

These were demonstrated as being isolated cases. In each case, a l comprehensive evaluation of cause and extent led to a positive conclusion which supported plant restart.

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"'$' c Q d Prior to restart,. additional long-term actions were defined to-further enhance the District's confidence in the' Phase 12 conclusions.- .These tasks, which'were defined as Phase 3, included the following:

6.- Technical. Evaluations for the remaining 75% of the Commercial-Grade Items in EQ Equipment.

7. Complete' review of previously prepared Commercial' Grade Dedication Evaluations which were based on like-for-like acceptance criteria.

8. Complete' evaluation of commercial grade items used in the Control Rod Drive Breakers, Reactor Protection System and its associated components.

9. Complete review of all Appendix B purchases to assure vendor understanding of 10CFR21 requirements.

These tasks are complete and the results confirmed that the safety function of installed equipment has not been adversely

~ impacted by past procurement practices. . Further, practices currently in place have incorporated the findings from these assessments, and will thus provide assurance that future procurement will support the1 Rancho Seco cbjective of safe plant operation.

This' report'contains a detailed discussion and conclusion of the final results for each assessment.

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2 e e d i 1.. O INTRODUCTION The Procurement Engineering Assessment Plan (PEAP) was developed to provide additional confidence to Rancho Seco management and the NRC that the as-installed configuration of Rancho Seco spare parts was consistent with plant safety requirements. The scope of the PEAP was later expanded to address other concerns identified by SMUD and the NRC. These concerns resulted from past procurement and material control practices. These practices were strengthened prior to restart through the implementation of the various improvement programs identified in this report. An expanded evaluation was conducted post restart to enhance the long-term performance of the material control process.

The Project consisted of three phares. Phase 1 was a review of plant problem reports and Phase 2 addressed the pre-restart evaluations of the use of material in safety related systems.

The results of Phases 1 and 2 were provided to the NRC in a report entitled " Procurement Engineering Assessment Plan Interim Report", dated March 1, 1988. Phase 3 is an expanded evaluation designed to enhance the long-term confidence in the ability of material procured under old material control processes. The results of this third phase, as well as a summary of the overall project, are presented in this final report. Actions which were required to be performed to provide assurance of the quality of spare parts have been completed as part of Phase 3.

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• U 2.0 CACKGROUND

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During December, 1987, SMUD's CEO, Nuclear directed the establishment of a Procurement Engineering Assessment Team with 4

an objective to evaluate past and current material control practices.and to recommend actions necessary for improvement.

The team was provided with resources as needed to successfully accomplish its objective. A Procurement Engineering Assessment Plan (PEAP) was formulated to describe the objectives and the specific methodology related to this effort. The initial objective of the PEAP was to provide Rancho Seco management-with enhanced confidence that installed equipment would meet design requirements. The PEAP was subsequently revised-to address additional concerns identified by SMUD and the NRC procurement _j team during their January, February and March 1988 inspections. '

The programmatic weaknesses identified and the corrective actions taken to resolve each are as follows:

J o Issue: SMUD Management identified the potential for

' improper use of Commercial Grade Items (CGI).

o Action: An evaluation of a random survey of installed Commercial Grade Items (CGI) was performed to assess the overall impact of past procurement practices for items used in safety related y systems. This program is discussed in Section 4.1.

o Issue: The NRC expressed the concern that past procurement practices for replacement relays may have adversely impacted the effectiveness of the Rancho Seco Seismic Qualification Program.

o Action: An evaluation of CGI relays installed in the i Reactor Protection Systems (RPS) and the Safety  !

Features Actuation' System (SFAS) was performed to assess the relay SEQ status. This program is 1

discussed in Section 4.2. i o Issue: The NRC expressed concern that past procurement practices may have invalidated SMUD compliance j

with 10CFR50.49, the EQ Final Rule.

o Action: An EQ Piece Parts evaluation was performed to l verify the acceptability of replacement parts l

originally procured as commercial grade and used ,

i for various EQ applications. This program is '

l discussed in Sections 4.3.

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W e a f ( ' .. o ICcu3: 'NRC inspectors raised-a concern that existing 4'

procedures for the procurement of spare parts needed to be enhanced to clarify and strengthen the controls for Class I, Procurement Level.3 r- activities.

o Action: The Programmatic Controls Task was performed to clarify and strengthen the controls forf procurement related procedures. This program is discussed in Section 4.4.

o Issue: The'NRC inspectors had a concern that Class I items which are available from the warehouse for installation in Class I systems might not be acceptable for use without further evaluation.

o Action: The Green Tag Program was implemented to provide assurance that acceptable documentation was available for Class I green tagged items. This program is discussed in Section 4.5.

o Issue: The NRC expressed concern that the past practice of dedicating commercial grade equipment based solely on equipment model number may have degraded safety system capability.

o Action: A reverification program was performed to provide assurance that itens dedicated and installed on a like-for-like basis did not adversely impact.the component's ability to perform its intended safety function. This program is discussed in Section-  !

4.6.

o Issue: Following the discovery of commercial grade undervoltage. devices (UVD) in the RPS, the SMUD CEO made a verbal commitment to the NRC to. perform ,

a 100% reverification of CGIs in the CRD breakers, RPS and its associated trip inputs.

l o Action: A reverification program was performed to review l CG equipment associated with the reactor trip function and to assure that such items were ,

appropriately dedicated. This program is '

discussed in Section 4.7.

o Issue: A concern was identified during the implementation of the Green Tag Verification Program regarding a  !

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number of purchase orders for Class I items that did not invoke the provisions of 10CFR21.

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. 4 o Acticn: SMUD contacted the suppliers who have appeared on the Approved Supplier List ( ASL) , informed them of the possible omission of Part 21 requirements in their purchase order, and requested written acknowledgement that 10CFR21 requirements were applied on all Class 1 items and services provided to SMUD. This program is discussed in Section 4.8.

Two additional tasks were subsequently included into the PEAP.

An evaluation of Agastat 7000 series commercial grade relays used in Class 1 equipment was performed in response to IE Notice 87-

66. This program is discussed in Section 4.9. An evaluation of potentially deficient fasteners whs performed in response to IE Bulletin 87-02. This program is discussed in Section 4.10.

It is important to note that a number of positive aspects regarding the suitability of installed equipment at Rancho Seco were identified. These were mainly highlighted in previously commissioned studies and programs which were related, either directly or indirectly, to materials management. These programs identified some deficiencies and contributed to improved practices. More significantly, these programs provided '

management with a high level of confidence that materials and equipment installed in the Rancho Seco Nuclear Generating Station  !

would perform their intended safety functions. These programs i included:

o Assessment of Materials Management Practices o System Review and Test Program (SRTP) o Expanded Augmented System Review and Test Program (EASRTP) o Engineering Evaluation of the Suitability of Installed Equipment However, the above programs and studies, as well as past audits, (both internal and external) did not focus specifically on Commercial Grade Item Dedication (CGID) . Due to past practices concerning this process, SMUD management decided that additional evaluations were desired to assess the impact of past CGID practices on plant safety and to again further enhance management's confidence in the adequacy of installed material and equipment.

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.- -.. 3. 0 '- CC3PE. DESCRIPTION-The Procurement. Engineering Assessment. Plan is a compilation of b ' improvement programs which'have been implemented to addresss concerns.and observations related to Procurement and Materials-Control issues at.the Rancho Seco plant. The objectives of the-project-were to:'

o Provide a highLdegree of confidence that the as-installed n

. requirements.

configuration of Rancho Seco is consistent with plant safety o Address concerns' identified by the NRC Procurement and Materials Control Inspection.

o . Ensure that long-term corrective actions designed-.to enhance the Procurement and Materials Contr.,1 processes are aggressively pursued.

The particular elements of the Procurement Project revolve around-the reverification of parts currently installed in the plant or stored in'the warehouse, and the actions necessary to assure'that future projects' adequately address quality issues related'to these parts. The elements of the project are listed below:

1.' Random Survey of Commercial Grade Items 2.

Seismic Qualification of Commercial Grade Relays-in.the Reactor Protection System (RPS) and Safety Features Actuation System (SFAS) 3.

Evaluation of-Commercial Grade Items Installed in Environmentally Qualified Equipment (EQ Piece Parts)

4. Enhancement of Existing Procedures and Training

5. Green Tag Program 6.

Like-for-Like Commercial Grade Item Dedication Evaluation (CGIDE) Reverification

7. Reactor Protection System (RPS) and Associated Components Commercial Grade Item Reverification

8. 10CFR21 Vendor Confirmation

9. Evaluation of Agastat Relays

10. Evaluation of Potentially Deficient Fasteners

11. QA Surveillance of Project Tasks Each of these elements are discussed in the sections that follow, with particular regard to objectives, scope, methodology, results, and conclusions.

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% 4.0 PROCUREMENT PROJECT ELEMENTS  !

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4.1  !

RANDOM SURVEY OF COMMERCIAL GRADE ITEMS 4.1.1 Obiective

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The Commercial Grade Item (CGI) Evaluation was. l initiated to provide an indication of the overall '

impact of past CGI procurement practices for items used in safety related systems. This assessment was  ;

designed to address various types of spares and l replacements procured and installed over the time l spectrum from 1978 to 1987.  !

l 4.1.2 Scope  !

A sample of work requests involving potential installation of commercial grade items in Class I systems during the period 1978 through 1987 was  !

' assembled. From this sample, a listing of work requests involving the installation of commercial grade items was generated. From this listing of work i requests, 57 were randomly chosen by the NRC during {

their Procurement.and Materials control Inspection of  !

January 4-14, 1988. These 57 were reviewed to assess !

the adequacy of the use of commercial grade items.  !

4.1.3 Methodology t i

For each of the 57 work requests selected by the NRC for inspection, a review package was developed which included the following information/ documentation:

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o A complete copy of the work request. >

o A copy of all material requests generated for the associated commercial grade material used.

o A copy of the purchase order (s) for the associated commercial grade materials.

o A copy of the warehouse stock issue record, o A copy of the Receipt Inspection Data Report, if available.

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1 Additional 'information was provided, including the following:

o Equipment test reports.

o Manufacturer's specifications.

,. o Catalog descriptions, o Manufacturer's Certificate of Conformance.

Each of the work request packages was then reviewed by L

the NRC during their January 1988 inspection to assess the adequacy of commercial grade item dedication practices historically employed at Rancho Seco.

The work requests selected by the NRC represented the installation of over 230 commercial grade items.

Specific commercial grade items associated with these packages included:

Part Description Part Description Snubber Parts Relays 0-Rings Pressure Transmitters i Solenoids Contacts Breakers Motors Bailey Modules Relay Grounds Sensors Flanges Inverters Set Screws Limit Switches Terminal Strips Packing Tape Transistors Gaskets Cap Screws.

Filters Zinc Nuts Sensing Lights Washers Ibbing Materials Valve Actuators Couplings Seal Kits Hydrogen' Catalyst Bed Valves Fuses Electro Wrap Bridging Connectors End Seals Splice Kits Conduit Rectifiers Integrated Circuits Meters Diodes Capacitors Switches- Pressure Regulators Potentiometers 90 Degree Elbows Wire Terminal Lugs Transformers 9

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( N 4.1.4 Results I

The NRC evaluation concluded that the practices I historically employed by Rancho Seco in the use of commercial grade items were satisfactory with the ,

following exceptions- i q

l o Work Requests 97391, 82120, 68932, 033177,-and j L 112230 contained commercial grade item dedications j based on like-for-like acceptance that did not include an evaluation of any design or l manufacturing changes that were made by the l Vender.

[j o Work Request 88694 - No certification existed .cn1 l COMSIP catalyst for hydrogen monitors. l o Work Request 45631 - No test acceptance criteria-  !

was specified for a circuit breaker. '

To evaluate these discrepancies, the Procurement Engineering Assessment Team developed Instruction ERT- {

05, " Engineering Evaluation of Previously Installed  :

Commercial Grade Items in Safety Related Systems". 1 This instruction delineated the process to be used in .I evaluating the impact of these CGI installations and, l where necessary, dedicating the items for Class I use. '

Using this procedure, all NRC concerns have been j resolved. A description of the resolutions of the ,

seven deficient work requests are as follows: j

1. WR 97391 - Ohmite Relay in the DCS Battery Charger This work request involved the replacement of a l relay in the battery charger. The vendor's bill

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of materials and recommended spare parts list 4 specified an Ohmite Model No. DOX-46T, 3  !

pole / double throw relay for this application. The  ;

current installed relay is'a commercially procured  ;

Ohmite Model No. DOX-480, 4 pole / double throw.

The dedication for this relay was documented as a "like-for-like" determination. It is unclear as to what point in time the relay type was changed.

No existing documentation which authorized the change in plant configuration from the originally supplied and qualified DOX-46T to the currently installed DOX-480 was found. Therefore, an NCR was written against this relay. To disposition the NCR a new commercial grade item dedication evaluation was performed. Based on an analytical  ;

systems evaluation, chatter evaluation, and a similarity analysis between the two relays, it was determined that the DOX-480 was acceptable for 10 I

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this application. The formal commercial grade item dedication has been completed and reviewed by the NRC.

2. WR 82120 - Wilmar Relay in the RCP Under Power Protection Cabinet in the RCS A review of the work history determined that the relay is no longer installed in the plant.

Therefore, no further analysis is required.

3. WR 68932 - GE Relay in the Reactor Sampling System This work request involved the installation of a commercially procured GE relay #GEF-4210 (CR2820A14AT-22). Dedication had not been performed in a satisfactory manner. The relay was subsequently dedicated by the District, based on a General Electric similarity analysis between the relay currently installed and a similar relay  :

installed in a motor control center that has undergone a qualification test. The final commercial grade dedication is therefore complete.

4. WR 33177 - Square D Relay in the SFAS H4SDB-00 Panel A review of the application of this relay disclosed that the relay is a spare relay and not in use. A procedure review verified that this spare could not subsequently be used without further evaluation. Therefore, no further analysis is required.

5. WR 112230 - Square D Relay in the SFAS H4SDA5 Panel This work request involved the installation of a relay that was procured commercial grade. A formal dedication had not been performed.

Subsequently, Square "D" provided a Certificate of Conformance in accordance with their approved QA program documenting that design and material changes of the replacement relay were insignificant and that the new relay was similar to the qualified relay. This certificate formed the basis for a commercial grade item dedication prepared in accordance with ERT-05. The formal commercial grade dedication has therefore been completed.

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WR 88694 - COMSIP Certification of the Catalyst for Hydrogen Analyzer Work Request 88694 replaced the existing catalyst bed in the hydrogen analyzer, Tag # AE-53811.

This equipment is subject to the requirements of 10CFR50.49. The work request package contained Purchase Order RS 55619 which procured replacement parts for the hydrogen analyzer as " commercial grade".

• The subsequent evaluation determined that the catalyst bed utilized in WR 88694 was actually procured under P.O. RS69500 rather than RS55619.

This was a QA Class I purchase which invoked 10CFR21. It also required a Certificate of Compliance that the material cupplied is equal in performance to those items originally supplied under Contract 8354, which were qualified based on EA&T Test Report 1035-1. Therefore, no further analysis is required to justify the acceptability {

of the installed equipment. 1 A review was conducted to assess why RS55619 was j originally included in the original package. The review determined that the incorrect P.O. had been identified by relying on the Stock card for Stock code #041560 which referenced several P.O.s including the correct one. Because it was determined that material bought under the P.O. in the original package (RS 55619) may have been installed in the plant (under a different WR), a further evaluation was done. To demonstrate the  !

materials acceptability, a new P.O. # RQ-88 16259 was issued to Comsip requesting a Certificate of Conformance to certify that the material supplied under P.O. RS 55619 was " equal to or better than the material originally supplied and is qualified to the requirements of IEEE 323-1974 and IEEE 344-1975 as documented in EA&T Test Report No. 1035-1, Revision 2". In addition, the certificate of conformance asked the vendor to certify that the material would not degrade the environmental qualification of the Hydrogen Analyzer. Using the resultant CofC a commercial grade dedication package was completed.

7. WR 45631 - Circuit Breaker A work history review has determined that the circuit breaker has been removed from service.

Therefore, no further analysis is required.

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4.1. 5 ~ Conclusions The evaluation of the set of 230 commercial grade item applications selected by the NRC for review resulted in questions on 7 specific items. As discussed above, in each case, these questions were resolved in a manner which demonstrates the' adequacy of commercial grade item dedication practices historically employed at Rancho Seco.

4.2 SEISMIC QUALIFICATION OF COMMERCIAL GRADE' RELAYS IN THE REACTOR PROTECTION SYSTEM (RPS) AND SAFETY FEATURES ACTUATION SYSTEM (SFAS) 4.2.1 Obiective The objective of this task was to assess the acceptability of commercial grade replacement relays installed in the Reactor Protection System (RPS) and the' Safety Features Actuation System (SFAS). .

4.2.2 Scope The work history of all relays in the RPS and the SFAS were reviewed to identify all relays which have been modified or replaced. The work history review disclosed that out of a total of 1,088 relays in the two systems, 29 relays had been replaced. These relays were evaluated to determine whether they had been properly procured.

4.2.3 Methodoloav l Nuclear Engineering Department Report ERPT-E0316 l

defines the methodology used to identify the total number of relays in the RPS and SFA5. The total number of relays in these systems was initially counted at 1114. The total number of relays in the RPS and SFAS was later reduced to 1,088 upon finalization and issuance of the report.

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Prior to restart, Equipment work histories for the 1088 relays were reviewed to identify those relays which had L been modified or replaced. This initial work history L

review identified 29 relays that had been installed for new applications or as replacement relays since installation of the systems.

A subsequent evaluation of 38-subcomponent tagged work requests resulted in the identification of 54 additional relays which had been installed in the safety related applications. These relays were identified in July 1988 as a result of a problem l

identified with the methodology used to develop the work history list on the EQ. Piece Parts Task. In the course of assessing the generic impact on other tasks, l

it was determined that the work histcry list used in the SEQ task was also flawed, since Work histories 't generated for subcomponents had not been included.

The total set of 83 relays have now been reviewed in accordance with procedure ERT-05. '

l 4.2.4 Results The evaluation of the relays disclosed the following:

1. of # BOUGHT # DETERMINED *

1. REQUIRING WR# RELAYS. CLASS I NO SAFETY IMP. CGIDEs Pre-restart evaluations:

33177 1 0 1 0 40321-24 9 0 0 9 50473 0 0 0 0 50469 12 12 0 0 68281 0 0 0 0 68282 0 0 0 0 60358 4 0 0 4 60376 0 0 0 0 112230 1 0 0 1 121655 2 2 0 0-121656 0 0 0 0 29 14 1 14 No dedication required.

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1. -of # BOUGHT # DETERMINED # REQUIRING WR# RELAYS CLASS I NO SAFETY IMP. CGIDEs J

Post-restart evaluations: 1

' 3476 6- 6 0- 0 4190 12 12 0 0 4276 1 0 0 1-6869. 0 0 0 0 7984 0 0

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0 0 l 12297 0 0 0 0.  !

13232. 0 -0 0 0 17712- 1 0 0- 1 17786. 0 0 0 0 19802 0 0 0 0 34080 0 0 0 0

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j 48032 2 2 0 0 1 48051 0 0 0 0 56515 0 0 0 0 56859 1- 0 0 1.

65956 0 0 0 0 78989 0 0 0 0 81042 0 0 0 0 4

81091 0 0 0 0 81092- 0 0 0 0

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81110 0 0 0 0 l 82997 0 0 0 0 85630' O O O 0 85641 0 0 0 0 90783 2 2 0 0 99966 1 0 0 1 101365 0 0 0 0 i 102565- 0 0 0 0 111640 0 0 0 0 115975 0 0 0 0 118540 0 0 0 0 118664- 2 2 0 0 125007 16 16 0 0 128416 8 8 0 0 131379 2 2 0 0 131435 0 0 0 0 134438 0 0 0 0 141982 0 0 0 0  :

54 50 0 4 l Total Relays 83 64 1 T5 A total of 3 CGIDEs were generated to dedicate the 18 relays as identified below:

CGIDE # # OF RELAYS 019820 10 023368 7 045660 1 16 4

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. Conclusions Based onLthe review of all 1,088 relays in the.RPS and SFAS,'and an assessment of the replacement relays, it was concluded that the.past use of commercial grade

' replacement relays did not adversely impact system safety.

4.3 COMMERCIAL GRADE ITEMS INSTALLED IN ENVIRONMENTALLY QUALIFIED EQUIPMENT (EQ PIECE PARTS) 4.3.1 -Obiective The objective of this task was to determine if past materials controls practices for procurement.and installation of commercial grade items'had resulted in the degradation of-environmentally qualified equipment subject to 10CFR50.49.

4.3.2 Scoce

.The EQ piece parts evaluation project was applied to all EQ replacement. parts which were installed in the plant since November 30, 1985. A work history; review indicated that for the 484 EQ equipment. tag numbers, 1085 work requests.were. issued,' 739 of which involved parts replacement'or modifications. The District committed to review 25 percent of these work requests

.before restart in accordance with the criteria established in ERT-05. The balance of the EQ replacement parts were to be reviewed by June 30, 1988.

l 4.3.3 Methodoloov The EQ Master List, as defined by Engineering Report l ERPT-E0177, was utilized to define the equipment tag numbers.whose work history would be reviewed. This i list-of tag numbers was subdivided into eleven categories based on equipment type.

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.a; g-For each equipment tag, a work history listing was generated to identify any modification or maintenance work that had been performed since-November 30, 1985.

Each work request was then reviewed to determine if parts had been installed. Those work requests.that involved replacement of items were evaluated per the requirements of ERT-05 to determine if a basis existed to demonstrate their ability to perform the required safety function.

4.3.4 Results At the end of the 25% sample effort, 186 work requests had been reviewed and dispositioned. 20 commercial grade item dedication evaluations were generated-to document the acceptability of parts found to have been procured commercially. A summary of the parts associated with the reviewed work requests in the approval cycle was as follows:

Total Work Replaced Parts Parts Parts Required Category Requests Parts .

Q1 CG NSR Replacement  !

MOVs 45 37 17. 11 9 0 Solenoids 32 32 17 10 5 0 Transmitters 29 16 7 6 3 0 Limit Switches 4 0 0 0 0 .0 Miscellaneous 27 3 3 0 0 0 Hydrogen Analyzers 18 16 1 13 2 2 Cable, Splices, O O O O O O Terminal Blocks Feedthrough 4 7 0 0 7 0 Penetrations Motors 11 6 1 3 2 0 H Recombiners 7 1 0 1 0 0 2

Acoustic Monltors 9 2 0 2 0 0 Totals 186 120 46 46 28 2 The District was able to justify the acceptability of all 46 of the commercially procured parts through the generation of 20 commercial grade dedication packages l

using the methodologies described in ERT-05, with the (

exceptions of the two parts. These two parts were '

I changed out prior to restart. Discussion on the two replaced parts is provided later in this section.

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Following restart the remaining 553 work requests were j

L reviewed in accordance with ERT-05. As part of the i completion of the remaining work requests, an effort 4 was undertaken to verify the validity of the original  !

list. During this effort, 290 additional work requests were added to the project scope. Many of those added were simply new work requests that had been generated after the original list but prior to the completion of training. Others had not previously been identified as a result of being archived under a " System Level" Tag #

(I.E. EFI-1 was used for work on the Emergency Feedwater System instead of specific Tag #). Still others were added because an independent check found that parts had been installed on work requests which previously had been determined to have installed no parts. The total scope of the EQ Piece Parts review therefore included 1,110 work requests to be reviewed by June 30, 1988.

I On August 12, 1988, a QA Surveillance conducted after l the completion of the EQ Piece Parts Task found that  !

the original work history list was incomplete. The original listing was developed from the plant's online ]

work control system "NUCLEIS". The QA finding i identified for the first time that the NUCLEIS data-base was incomplete. The database included all work  ;

requests generated since June 1987 (the initiation of NUCLEIS) but only a small set of previous work requests that had been downloaded from the old work control system, MIMS. The downloading of MIMS to NUCLEIS in June 1987 was found to include only work requests which j were still "open". " Closed" work request data was j downloaded directly onto magnetic tape and archived without being loaded onto NUCLEIS. This meant that some work requests generated between November 30, 1985 and June 1987 were not included in the original listing because they had been closed prior to the downloading .

of MIMS to NUCLEIS.

Following the identification of this problem, a new, i full list of work requests written against EQ equipment ]

between November 30, 1985, and April 30, 1988 was i generated using the Rancho Seco records data base

" STAIRS". This new listing was compared to the original NUCLEIS list to delete those which were i already addressed in the original scope. This effort resulted in the addition of 1507 work requests which had not been evaluated in the original scope. These work requests have all now been evaluated in accordance with tne project procedure ERT-05. The total number of work requests evaluated during the EQ Piece Parts Task was I therefore 2617.

A summary of the final results is provided below:

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.O s-1 Total Work Replaced Parts Parts Parts Required-Category Requests Parts CG l

__ Q 1 NSR Replaceme MOVs 1572 2750 985 1046' 719 2 Solenoids 94 58 32 20 6 0 Transmitters 407 306 125 161 20 0 Limit Switches 19 1 0 1 0 0 L

Miscellaneous 298 39 23 13 3 0 Hydrogen Analyzers 50 35 7 25 3 2 Cable, Splices, 34 116 66 39 11 0 Terminal Blocks Feedthrough 35 33 14 7 12 0 Penetrations Motors 89 82 27 37 18 0 H Recombiners- 10 12. 7 4 1 0 2

Acoustic Monitors 9 4 0 2 2 0 Totals 2617 3436 1286 1355 795 4 The post restart EQ Piece Parts Review resulted in the generation of an additional 51 commercial grade dedication evaluations bringing the total number of dedications to 71 for this task. Also, one additional part which needed to be replaced was identified.

Each of the four part replacements are described below as well as the results of root cause analyses and generic impacts. A listing of all !!CR/PDQs generated during the PEAP is provided in Attachment 1.

1) NCR 7772 - ASCO Coil in the Hydrogen Monitor Solenoid The hydrogen monitor panel H-4HMB contained a solencid valve with an incorrect coil. The coil was not the high temperature Class H coil which had been qualified by the vendor in EA&T Test Report 1035-1. As a result, the coil in question was replaced prior to restart. Investigation of this condition and the associated root cause determined this to be an isolated occurrence in that the stock identification number for the coil applies only to coils used in the hydrogen monitors and the stock code inadvertently omitted the designation "THT"'as a prefix to the 19 l

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manufacturer's coil number.

A further review of all solenoid valves in EQ applications indicated no other occurrence of this condition, nor was there. any evidence of incorrect stock card designations in any of the other work requests reviewed.

2) NCR S-7788 - Wiring in the Hydrogen Monitor Cabinet Heater The containment hydrogen monitor local panel (H-4HMA) contained power wiring to the heater elements that was not in conformance with the vendor drawings. The vendor supplied wire was replaced with 14 gauge SIS nuclear grade wiring rather than the required 16 gauge BIW silicone wire. '

The wiring used was determined to be #14 AWG Rockbestos Firewall SIS 600V wiring which is rated at 90 degrees C. This wire was installed because it was known by maintenance personnel to be

" qualified to the requirements of IEEE-383".

Qualification however is dependent upon the specific application. The manufacturer of the hydrogen analyzer (COMSIP, Inc.) informed SMUD that all wiring located in the heated sample compartment (hot box) of the containment monitoring system installed in Rancho Seco must be 16 gauge BIW silicone wire (the originally qualified wiring) if qualification is to be i maintained. j During a walkdown of the hydrogen monitor in  !

l March, 1988 it was obcerved that the insulation on the installed Rockbestos Firewall SIS and AMP lugs  !

inside the hot box assembly had in fact i deteriorated due to over heating. It was visually apparent that this wiring was incapable of

' withstanding continuous exposure to the temperature environment in the hot box assembly (285 to 300 degrees F).

As a result of this condition, an NCR was generated and dispositioned to replace the wire.

An analysis concluded that this conditio's was isolated. The basis for this determination was that the specific vendor drawing was ambiguous and lacked design information for the wiring routed inside the hot box assembly. Improper wiring was utilized because information was not available to aid in the selection and inspection of the wiring.

To assure that this condition did not exist in the other analyzer (H-4HMB), a review of work history and a walkdown was performed. These reviews concluded that no wiring changes have been performed and the proper wire is installed.

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3) PDQ-88-00016, PDQ-88-1155 and PDQ-88-2028 -

Limitorque Motor Pinion Key Replacement The traceability of the motor pinion key for two-Class.1 Limitorque actuators could not be established. No documentation of the applicable purchase order or pedigree of.the key. stock was available from the work request or maintenance personnel. The. motor pinion keys have subsequently been replaced with fully qualified keys.

In addition to the four parts replacements' identified above, one additional PDQ was written.whose disposition is to replace parts. PDQ-88-1595 identifies a lack'of traceability to purchase documentation for a motor shaft lip seal and a torque. switch on a Limitorque operator. The PDQ disposition of interim accept, long term replace was justified based on an operability review of the actuator.

4.3.5 Conclusions Based on the results'of the review of 2617 work.

requests and the disposition of,the associated NCRs and PDQs, it has'been concluded.that past procurement practices have not affected the reliability of safety related equipment subject to the requirements of 10CFR50.49.

4.4 ENHANCEMENT OF EXISTING PROCEDURES AND TRAINING-4.4.1 Obiective The procedure enhancement effort was undertaken to clarify and strengthen the controls provided by procurement-related procedures. Procedures related to the control of procurement level 3 and 4 purchases were emphasized.

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4.4.2 Scope The enhancements were made to clarify and strengthen  !

the controls for Class I, Procurement Level 3 and 4 activities. This included reissue of the procurement level control procedure in a plant level procedure and the addition of supplemental guidance for engineering evaluation of Level 3 and 4 procurelaent items. In addition, other procurement-related procedures were reviewed to resolve noted discrepancies in relation to incorrect references, especially those related to procurement level 3 and 4.

4.4.3 Summary of Revisions The following is a brief synopsis of revisions made to the Material / Procurement Control procedures. Titles for these procedures are provided in Table 4.4-1.

MMP-0022 Updated the Reference Section.

MMP-0023 Updated the format to latest MMP-0024 requirements.

MMP-0028 MMP-0026 (Four Level Procurement System) - This procedure has been superceded by RSAP-0408.

RSAP-0401 Updated the Reference Section. I Updated the format to the latest requirements.  ;

RSAP-0403 }

Issued PCN to update the Reference '

Section.

RSAP-0405 Updated the Reference Section and Format. Replaced Attachment 4 to f reflect the latest revision of a

" typical" RIDR.

RC77-0701 Updated the Reference Section and updated the format to the latest requirements. PCN-2 was insued to allow for QC logging of bulk items removed,  !

3 and to change terminology from an NCR to l PDQ. I RSAP-0704 Updated the Reference Section and updated the format to the latest requirements. PCN-01 was issued to allow reclassifying material bought CG and to change terminology from NCR to )

PDQ. 1 22 1

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MMP-0021. Updated the Reference Section and.

format. Revised Attachment 3-(standard clauses), Page 3'of 10, to revise the 7 option that a supplier could provide an

' item as Commercial Grade on a Procurement Level 1 or 2 Purchase' Order.

In doing this,.the supplier will be required to document their request on

'the SDR, thereby obtaining Engineering evaluation prior to shipment.

RSAP-0706' Added a definition for a " Generic Dedication". Deleted separate reference to EQ/ SEQ items - these items have the-same requirements as QA Class'I items.

Deleted all Generic Items which were listed as not' requiring dedication -

these items will now be dedicated on a l

Commodity. Material Evaluation (CME) as a l

" Generic Dedication".

RSAP-0808 Identified criteria established by Nuclear Engineering during the procurement review process. Revised the terminology from NCR-to PDQ, and to define tagging requirements for PDQ items.

NEAP-4202 Updated the Reference Section and Format. Removed-the CME Review methodology which was added into NEAP-i 4205.

NEAP-4205 Updated the Reference Section and Format as well as the following changes:

o A Quality Related Item Evaluation '

review was added to address the '

definition of characteristics important to function for items being purchased through Procurement Level 3 & 4. Strengthened the method by which the critical characteristics are defined / verified prior to procurement, and added the CME review methodology related to the QRIE. i o Eliminated like-for-like <

verification based solely on model  ?

number as a means to accept a j commercial grade item. Critical i characteristics for identical replacements are required to be i verified.  !

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MMP-0025 Updated the Reference Section and the format to latest requirements. PCN-7 was generated and required extensive changes to account for special storage /

maintenance requirements including:

tagging; documentation; inspections; use of special desiccants; storage area personnel access; and added a reference to special Storage Instruction (MTL-013) as well as personnel responsibilities.

RSAP-0408 This procedure replaces MMP-0026 and was expanded to include:

1. Expanded scope to clarify the type of equipment / components / items applied to the Four Level Procurement System.

2. Added Definitions for C of C, Services, Surveillance, Test, Source Inspection and Commercial Grade Item.

3. Added Responsibility Section to clearly delineate responsibilities I to Procurement Engineering, Quality Engineering and Nuclear Engineering with respect to reviewing, evaluating and approving  ;

procurement documents.

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4. Revised description of Procurement f Level 3 (Verification Method) to j clarify type of procurement this  ;

classification is applicable to, l the methods by which the items can

{

be accepted, and the approvals  :

required for this type of purchase. j

5. Added two new attachments to identify review responsibility and i specific procedures to be implemented for each review responsibility. Added a table to illustrate examples of each type of purchase, required approvals, method of acceptance and applicable procedures governing each review.

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h. l d^, , 6. Addressed the transmittal of supplemental inspection and/or- j' testing requirements and acceptance i criteria - the Planning Department for incorporation into applicable l l

work request (s). This. applies to l post-receipt or post-installation testing, QC Hold / Witness points in work requests to verify R acceptability of an item.

QAIP-0701 Updated the procedure to clarify the initial supplier approval process. 'The

. paragraph allowing unrestricted l

placement on the ASL immediately after a successful audit has been eliminated. A-reference has been added to identify NRC ,

Inspection Report 88-02 and commitments made in CGA-88-065.

I 4.4.4 Trainina of Personnel A comprehensive training program was implemented for

' Engineering and Material Control / Procurement and Quality personnel. The program covered Procurement and Engineering evaluations, particularly Commercial Grade Item Dedication and the Class I, Level 3 & 4 purchase process. It provided an overview of the four level procurement system. The Technical Staff Training group of the Nuclear Training Department provided assistance for the development of training materials, guidance for proper formats and training processes, coordination of time and training location and process of the i attendance records through the system consistent with existing Training Department procedures.

4.4.5 Conclusions i

Procedures related to procurement practices at Rancho Seco have been enhanced to preclude the use of inappropriate material in Class 1 systems.

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1. . . -TABLE.4.4-1 TITLES OF REVISED PROCEDURES RSAP-0401 PREPARATION AND PROCESSING OF PURCHASE REQUISITIONS RSAP-0403 PROCESSING OF BLANKET PURCHASE ORDER AGREEMENTS l RSAP-0405 QUALITY RELATED ITEM REVIEW RSAP-0408 FOUR LEVEL PROCUREMENT SYSTEM RSAP-0701 ISSUE AND RETURN OF ITEMS TO STORAGE RSAP-0704 STOCK RECLASSIFICATION REQUIREMENTS EVALUATION RSAP-0706 DEDICATION OF COMMERCIAL GRADE ITEMS RSAP-0808 QC INSPECTION '

NEAP-4202 PROCUREMENT DOCUMENT REVIEW

.)

-NEAP-4205 COMMERCIAL GRADE ITEM DEDICATION EVALUATION MMP-0021 TECHNICAL AND QUALITY DETERMINATION FOR.

PROCUREMENT DOCUMENTS MMP-0022 PROCUREMENT MMP-0023 RECEIPT OF ITEMS MMP-0024 IDENTIFICATION AND MARKING OF ITEMS  !

MMP-0025 PRESERVATION, STORAGE AND MAINTENANCE OF ITEMS IN  !

STORAGE MMP-0026 FOUR LEVEL PROCUREMENT SYSTEM '

MMP-0028 RECEIVING, STORAGE, HANDLING AND ISSUANCE OF HAZARDOUS MATERIAL QAIP-0701. APPROVED SU.PPLIER LIST

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/, , 4.5 GREEN TAG PROGRAM 4.5.1 Obiective The objective of the " green tag" program was.to provide assurance that Class I items which are available from the warehouse (s) for plant installation in Class I systems were adequate for use without any further technical and/or quality evaluations.

The scope and methods for' implementing the program are described in Instruction ERT-06,." Sample Evaluation of Class I Warehouse Stock currently Available for Issue".

4.5.2 Scone In order to provide the assurance that " acceptable" Class I items in the warehouse have'the required-supporting documentation, a program to survey such items was implemented.

The survey was to encompass approximately 100 items which were in the warehouse, procured prior to

. implementation of the current procurement program (1987), tagged as Class I, and available for issue without further evaluation.

4.5.3 Methodology l

In order to provide a representative survey of items, as well as satisfy selection criteria consistent with existing procurement guidelines and/or instructions, the following methods were utilized:

a. Walkdown of the warehouse (s) was performed to l . physically locate and examine existing stock items which satisfied the following criteria:

1 Items with " green tags" designated as Class I, non-commercial grade.

All required " green tag" information  !

necessary for issuance from the warehouse (s) was' completed.

" Green tags" were not missing or mutilated.

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b. To ensure that the selected group was representative, items.were chosen from over 20 vendors, which were purchased between the years of 1974 and 1986, and for various plant systems,

c. An effort was also made to: 1) provide a group consisting of approximately 70% electrical items and 30% mechanical items (per NRC request), and 2) minimize the number of multiple items procured under the same purchase order even if.the items were of different stock code. numbers.

Items " green tagged" but identified as commercial grade were'not included in the survey because they were being addressed by other aspects of the procurement project.

After identification of " acceptable" items for the i

j survey, individual documentation packages were prepared for each of the items. All packages were reviewed by l Procurement Engineering and Quality Engineering. If necessary, packages were reviewed by Nuclear Engineering for appropriate EQ/ SEQ documentation. l 4.5.4 Results It became evident during the sampling process that'it would be difficult to obtain a group of 100 items which satisfied the selection criteria. After discussions with the NRC, the Sample selection was completed with a total of 75 Stock Code Numbers being evaluated. The NRC concurred with the scope selection methodology.

The NRC's acceptance was based on the fact that the sampled. group represented a high percentage of the total items available for issue which satisfied the selection criteria.. Of the 75 items selected, 43 items were electrical and 32 were mechanical. This represents approximately 58% electrical and 42%

mechanical items.

Five potential problems were identified with the material reviewed. Two of these problems resulted in the issuance of Engineering Action Requests (EARS), NE 88-016 and NE 88-017. There was no history of material issue to the field, and EARS were generated simply to request an engineering evaluation as to the acceptability of the existing procurement and equipment  ;

qualification documentation for future installation.

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For NE 88-017 the procurement documentation did not address all of the items in stock for that particular stock code (SCN 105056), ie. five items were on hand but procurement documentation addressed only four. The items appeared to be identical in fit, form and function, but because of incomplete information on the green tag it was not possible to trace each of the items back to its original purchase order. The evaluation dispositioned the material reject and the stock was sent to salvage.

For NE 88-016 the material received and in stock was proper for its intended application and was acceptable for use'in a Class 1 application.

In addition to the Engineering Action Requests, three Non Conformance Reports (NCRs) were written against stock code numbers where parts were installed and where documentation appeared to be inadequate. These NCRs were S-7761, S-7769 and S-7820. The evaluation and disposition process for each of these NCRs either established the acceptability of the availrble documentation, provided additional supporting information from the vendors or provided technical j evaluations to substantiate the existing material '

quality.

As part of this effort, the NRC requested that the District verify that the suppliers of the 75 items had an approved QA program implemented at the time of 1 material purchase. Verification was performed in one '

of the following forms:

o A SMUD QA Implementation Audit  !

o An ASME Certificate l o Listing identified in the CASE Register o Obtaining a copy of an audit report from another nuclear utility or other acceptable source.

Hold tags were placed on several stock items which were not reviewed by restart. All suppliers where ultimately verified by one of the above methods as having implemented acceptable OA programs for the time periods in question.

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4.5.5 Conclusions j As the result of the warehouse walkdowns conducted for i this survey, it is' estimated that a majority of the 1

Class I items which could be issued to Class I l applications were reviewed. Although the group ~ size is smaller than expected,-it' represents a large percentage of the items available for issue without-any further ]

review, thus providing increased assurance of the J acceptability of the items available.

Five items were found to have documentation j deficiencies. These have been evaluated by Nuclear I Engineering and dispositioned as acceptable.

WithLthe exception of one issue, relating to a failure to impose 10CFR21 requirements on purchase orders, no significant items were noted during this review. The i 10CFR21 issue was successfully addressed as a separate {

task of the Procurement Project'(,see Section 4.8). l Adequate assurance has therefore been provided to 4 demonstrate that Quality Class I warehouse items j available for issue have the required procurement and inspection documentation. I 1

4.6 LIKE-FOR-LIKE COMMERCIAL GRADE ITEM DEDICATION EVALUATION (CGIDE) REVERIFICATION 4.6.1 Obiective

'l 1

The objective of this task was to reverify the validity 1 of all Rancho Seco Commercial Grade Item Dedication i Evaluations (CGIDEs) initiated since September 1987 which were based solely on a part number like-for-like basis. Like-for-like dedication was a procedurally approved methodology between September 1987 and the time of the NRC audits. NRC inspectors indicated that this approach did not comply with the intent of commercial grade dedication practices accepted by the NRC, irt that consideration was not given to material and design changes that may have occurred with the I

respective CGI. This task was initiated to provide assurance that the like-for-like methodology did not adversely impact plant safety functions.

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f, , 4.6.2 Scope A review of all CGIDEs completed after September 1987 was made by Procurement Engineering. This assessment identified a list of 257 CGIDE packages for items previously dedicated using the like-for-like acceptance methodology. The list was subsequently reduced to 256 CGIDE packages. These packages were then re-evaluated in accordance with Procedure ERT-05.

4.6.3 Methodoloov The methodology for conducting this task involved Implementation of Procedure ERT-05. The purpose was to perform engineering evaluations of as-installed )

j commercial grade items in safety related systems to l assure that the critical characteristics of the  !

replacement parts were equal to or better than the  !

original equipment. Each critical characteristic was verified by objective evidence and appropriately 1 documented.

I 4.6.4 Results 1

Re-evaluation of 24 CGIDEs were completed prior to plant restart. With the exception of six complex packages, the remaining packages were completed by April 30, 1988.

Five of the remaining six packages were completed by May 31, 1988. One dedication package associated with the Bruce Diesel Generators was completed by July 31, 1988. The results of the re-evaluation indicated that in every case, critical characteristics could be verified.- None of the 256 commercial grade dedication packages that were evaluated resulted in the identification of any parts that could not to be  !

dedicated. '

4.6.5 Conclusions Based on the above assessments, it is concluded that the practice of dedicating equipment based solely on equipment model number did not degrade safety system capability.

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d. 4.7 REACTOR PROTECTION SYSTEM (RPS) AND ASSOCIATED COMPONENTS COMMERCIAL GRADE ITEM (CGI) REVERIFICATION 4.7.1 Obiective On March 28, 1988, the CEO-Nuclear made an oral commitment to the NRC to perform a review of all

. commercial grade items installed in the Reactor Protection System. The action was initiated upon1 discovery of unmedicated commercial grade under-voltage devices in the reactor trip breakers just prior to restart. Because of past procurement practices, SMUD desired to enhance their confidence in the-overall use of_ commercial grade items in the Reactor Trip Systems at Rancho Seco.

4.7.2 Scone The scope of this task was to review equipment associated with the reactor trip function. The review determined the extent and application of commercial grade items installed in reactor trip functions and whether they could be appropriately dedicated.

The scope of equipment included all equipment associated with the RPS trip function defined in the USAR.

The RPS, as defined in the USAR, consists of four identical protection channels housed in eight cabinets with each terminating in a trip relay within a reactor trip module. The boundary of the review encompassed the eight reactor protection cabinets, as well as the reactor trip breakers which carry out the trip function when the RPS actuates. In addition, other components which provide input signals or manual trip function also were included in the scope of the review. These signal generating components are the reactor building pressure switches, reactor coolant pressure transmitters, reactor coolant temperature elements, main feed pump oil pressure switches, turbine auto stop oil pressure switches, neutron detectors, reactor coolant flow transmitters, reactor coolant pump monitors, and the console mounted manual trip switches.

The task encompassed a complete work history review of all components described above. Identification of the {

associated equipment tag numbers is shown in Table  !

4.7-1.

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{l} . .- 4.7.3 Methodology The evaluation of commercial grade items installedIin

" the Reactor Protection System, as defined in Section 4.7.2,-employed the.following methodology:

1)' Perform'a_ complete. work history evaluation.to identify if any commercial grade items have been installed in the scope equipment.

-2) If commercial grade items are found to be currently installed in scope _ equipment, perform an evaluation of the adequacy of the commercial grade items in accordance with Procedure ERT-05.

3) If any installed commercial grade item could not be dedicated, a PDQ was generated to document the potential quality problem. If a justification for the part's continued use could not be developed,-

then the part was to be replaced or otherwise declared inoperable. A generic implication evaluation, if appropriate, was required to be completed.

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TABLE 4.7-1 g

SCOPED RPS EQUIPMENT NUMBERS FOR REVIEW PROCESS l

' Equipment Description SMUD' Equipment Number Remarks RPS Channel.A, B, C and D cabinets H4PR 1A/2A/1B/2B/1C/2C 8 Section Cabinet 1D/2D includes-NI/RPS instrumentation Reactor. Trip Breakers CB-1/2/3/4, CRD-A/B RB Pressure Switches PSH-53606, 53620, 53617, 53619

.C.

R Pressure Transmitters- PT-21038, 21040, 21037, 21039 RCfTemperature Elements TE-21034, 21030, 21033, 21029

-RC. Loop Flow. FT-21027A/B/C/D,

. Transmitters 21028A/B/C/D RC Pump Monitors Device 210-1,2,3,4,5,6,7,.

Relays. located.in 8,9,10,11,12,13,14,15,16 Cabinet H4UP Console Mounted Manual Device-75 Trip Switch Located in Consol H1RC MFP Gov.' Oil Pressure PSL-31711, 31712,

' Indicators- 31713, 31714, 31715, 31716, 31717, 31718 Turbine Auto'Stop Oil PSL 30182, 30183,

-Pressure Indicators 30184, 30185 Neutron Detectors XE-00406, 00407, 00408, 00409 '

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gj , - 4.7.4 Results

The evaluation of-the RPS/CRD Commercial Grade Item Reverification resulted in the review of 633. work requests in accordance with procedure ERT-05. .A total of 38 commercial grade dedications were generated and two dedications revised.

There were five (5) work requests for the CRD breakers that could not be retrieved from plant records. This was.also identified and responded to in QA surveillance observation QA-88-S-550-02 (0) . Work requests P24037, P24089, P24090, P24091 and P24092 are listed in MIMS archive reports on microfiche but are not retrievable through the Records Information Center'(RIC).

Review of MIMS. history of work requests in question results in the conclusion that the missing work requests were never sent to plant records because the work requests performed the same work, on the same day, for the same equipment. Therefore, it was concluded that these work requests are duplicates which have already been reviewed during the original RPS scope.

The exclusion of the missing work requests does not impact the 100 percent reverification.

QA Surveillance observation 88-S-550-03 (0) identified that during the evaluation of RPS work requests for-reverification of commercial grade parts, the evaluator failed to address an AMP splice and a terminal board identified in work requests 73171 and 121393, respectively.

A detailed review of work request 73171 indicates that STA-KON butt splices were used as indicated on page 2 of the work request and there is no indication within the work request that AMP splices were used. Work request 121393 installed the terminal board and was

-inadvertently missed during the work request evaluation per ERT-05. The terminal board used in work request 121393 was previously dedicated for use in H-4PRIA cabinet (CGID No. 036803, Curtis type FGTX-12 terminal block). The work request disposition sheet for work request 121393 was subsequently revised to address the terminal board.

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.CGIDE: package 016978 for Alpha' wire identified that the incorrect purchase order number was referenced on the RIDR and the green QA acceptance tag. RIDR No. QA-L 4445, inspected multiple stock' items purchased on.

'various purchase orders. It appears that the RIDR was

. originally prepared for several wires purchased on P.O.

RS-64144'and it was subsequently. corrected to add / delete several stock codes and add P.O. RS-71755.

It apparently'omitted P.O.s RS-44691 and RS-78859.

However'the completed RIDR had a copy of Alpha and i

Belden Wire catalog pages attached to it. Based on the green tags and a blue memo attached to the work-request, three wires (SCN 016063, 016058 and 016978) were used from the wires inspected per RIDR QA-4445.

The unmedicated undervoltage devices in the CRD breakers, which originally initiated this task, have been replaced by Class 1 UVDs originally-procured under P.O. RQ-88-07-29357A. These replacement parts have been evaluated in response to CCTS T880505006 in

-engineering report ERPT-E0371.

'Four PDQs were generated as a result of this task. PDQ 88-1427 was initiated because there was insufficient traceability to the part manufacturer and insufficient documentation to determine the method of procurement for parts installed under four (4) work requests. -The items installed were a U-bolt (WR No. 46832), wedge 1 anchors and bolts (WR No. 46833), and jumper wire (951 No.s 74449 and 133628). The PDQ is currently assigned to Nuclear Engineering for final disposition.

PDQ 88-1466 was initiated because the identification number of the flow transmitter replaced in the plant is not the same I.D. number as indicated in the work request.

This PDQ also identified that these flow transmitters which are located in the reactor building (but are not subject to 10CFR50.49) did not have a qualification file to document the suitability of this equipment in the radiation environment to which they are exposed.

As a result, a GDC-4 file (ERPT-E0360) was assembled using the DOR guidelines as a basis to document the suitability of the RCS flow transmitters.

PDQ 88-2030 addressed four (4) work requests which installed untraceable electronic components utilized in the RPS modules. These items were subsequently accepted based on the results of tech spec related surveillance testing of the RPS.

PDQ 89-0025 was written to address untraceable power supplies used in the RPS. The disposition of this PDQ establishes that the power supplies were supplied by B&W as QA Class 1, per Field Change Package 04-3191-02.

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4.7.5 Conclusions Based on the evaluations of the RPS/CRD Commercial Grade Item Reverification. Task, it is concluded that past procurement practices involving commercial. grade items have not degraded the seismic qualification of relays installed in the RPS and SFAS. .Similarly,.it'is also concluded that the past procurement practices of commercial grade items has not degraded the ability of the Reactor Protection System and its associated-components to perform their safety related function.

4.8 10CFR21 VENDOR CONFIRMATION During implementation of the Green Tag Verification (Section 4.5), a number-of purchase orders for Class 1 items were i discovered to have been issued without specifying the applicability of the provisions of 10CFR21. SMUD initiated i the 10CFR21 Vendor Confirmation task to contact all the  !

suppliers who have appeared on SMUD's Approved Supplier List I

( ASL) , inform them of the possible omission and request written confirmation that 10CFR21 requirements were-imposed on all Class 1 items and services.

4.8.1 Obiegtive The objective of this task was to obtain acknowledgement from suppliers that they understand their obligations pursuant to the provisions of 10CFR21 for all Class I items and services supplied to SMUD.

4.8.2 Scope All suppliers who have appearea on the SMUD ASL spanning the period 1978 to 1986 were to be contacted.

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T.. .4.8.3 Mgthodoloav-The first step required identification of all. suppliers who would have provided Class 1 material to Rancho Seco within the specified time frame. All of the ASLs since 1978 were compiled into a Master List which contained over-700 company names. This master list included multiple entries for'the same company with different locations / branches. Subsequently, a decision was made to eliminate these duplicate entries and contact the corporate headquarters. .This reduced the list to approximately 560 names which comprised the initial Master ASL requiring vendor contact.

SMUD sent'a letter to the suppliers requesting acknowledgement of their understanding of obligations imposed upon them to comply with the reporting requirements of 10CFR21 for Class 1 items and services supplied to Rancho Seco. It should be noted that the greater majority of the vendors are established suppliers to the nuclear industry'and are therefore familiar with their Part 21 responsibilities.

ERT-07, " Control of Part 21 Letters", was developed, describing the methodology for controlling, evaluating and dispositioning the vendor responses. When the initial responses were received, it was determined that many would require follow-up contact and evaluation.

Several were identified as likely candidates for not responding, not being located or out of business; therefore, alternate methods to resolve these items were required.

A second request was prepared by SMUD and transmitted to the vendors who had not yet provided a response.

Concurrently, for those vendors who could not be located, a request for assistance in locating the  !

suppliers was distributed to other utilities via the INPO Nuclear Network System (NNS). Responses to NNS either directed SMUD to the companies where contact was made, or provided assurance that vendors were no longer in existence. Leads were also obtained through use of personal industry contacts.

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i 4.8.4 Results All vendor response evaluations are complete, the final total of vendors on the Master ASL which could be evaluated was 532. Other vendors were unable to be located or determined to be out of business. The following is a tabulation of the evaluation results:

Category Total Disposition 1 10 CFR21 Responsibility 292 Acceptable Acknowledged 2 Implied Understanding of 76 Acceptable 10CFR21 Responsibility 3 Supplied No Class 1 Material 162 Acceptable Other 2 Acceptable Total 532 4.8.5 Conclusion Based on evaluation of the vendor responses and subsequent purchase order research for those unable to be located or determined to be out of business, it is concluded that SMUD's failure to impose 10CFR21 applicability on some purchase orders has not resulted in the receipt or installation of suspect material.

All material was receipt inspected and accepted based on supporting quality documentation. SMUD has always and continues to be responsible for Part 21 notification components.

of failures associated with all basic 39

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4.9 EVALUATION OF AGASTAT RELAYS 4.9.1 Obiective The objective of this task was to evaluate the qualified life of Agastat 7012, 7014, 7022, 7024, and 7032 series commercial grade relays manufactured by the Amerace Corporation. This task was performed in response to IE' Notice 87-66.

4.9.2 Scone The scope of this task was to evaluate all commercial (

grade Agastat relays installed in Class 1E equipment at Rancho Seco. Discussion with Electrical Engineering and a review of applicable drawings identified a total of 54 commercial grade Agastat 7000 series relays installed in the following Class 1 applications:

o Bruce GM Control Cabinets o 4160V Switchgear o 480V Switchgear o 480V Motor Control Centers 1 o CR/TSC Condenser Units o NSEB Condenser Units None of these applications fall under the requirements of the EQ Final Rule, 10CFR50.49.

4.9.3 Methodoloav Contact with Wyle Laboratories in March, 1988 indicated that Wyle has performed numerous tests on Agastat 7000 series comuorcial grade relays with favorable results.

The list of relays tested by Wyle, as communicated to Rancho Seco, encompasses the Agastat 7012, 7014, 7022, and 7024 series relays, as well as the GPIE 7000 series, SPDE 7000 series, TE series mad ML series.  !

Rancho Seco currently has installed 7012, 7014, 7022, (

7024, and 7032 series relays from the 7000 series. j Also installed at Rancho Seco are 2412, 2414, 2422, i 2424, EGRI, E7012, E7072, and E7024 series relays. As indicated, the 7000 series relays installed at Rancho Seco are enveloped by the 7000 series relays tested by Wyle, with the exception of the 7032 series. There are seven (7) Agastat 7032PAA relays currently in service ,

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To complete the analysis, an Agastat relay, model

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7032PAA,.was sent to Wyle Laboratories for seismic testing and for thermal and mechanical aging analyses-to determine the expected life of the relay.

4.9.4 Results.

The Wyle report was received on July 8, 1988 and'has been reviewed by the staff of the Procurement Project, Electrical Engineering and EQ. The results of.the Wyle report indicate that the five (5) 7032 relays located in the Auxiliary Building have an expected life of 40

years. The Wyle report was then evaluated to determine applicability to the two remaining 7032 relays (located in the Bruce Diesel Generator Room) along with the other forty-seven (47) 7000 series CG relays installed in the plant. This was accomplished by determining the non-metallic materials used in the manufacture of the relays and the environmental conditions under which the relays must function. An expected life naalysis was then performed to determine if and when the replacement of any relays was required.

The follow-up Wyle aging analysis of the 7032 relay encompasses the following areas:

o Radiation o Operational cycling o Time / Temperature Effects o Synergistic Effects o Relative Humidity o Pressure o Vibration The aging mechanisms evaluated in detail in the Wyle Labs report are Radiation, Operational Cycling and Time / Temperature Effects. Relative Humidity and Pressure were excluded from the evaluation as no known aging mechanisms exist for these parameters. Vibration effects are accounted for in seismic qualification and no synergistic effects were identified. The two remaining 7032 relays were analyzed and it was determined that these relays are also qualified for in excess of 40 years. The results of this analysis are provided in Report ERT-12, Revision 1.

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(i The' evaluation of'the Agastat 7012-7024 relays was accomplished in the-following nanner.

l o, Determine the non-metallics used in the 7012-7024 i series CG1 relays. I o compare the non-metallics list of the 7012-7024 series CG relays to the non-metallics list of the 7032 series CG relays evaluated 1in the Wyle report.

o' Determine the environmental conditions for the remaining forty-seven (47) relays.

o Perform expected life calculations.

The results of the aging analyses for these relays is L as follows.

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The thirteen (13) relays located in the Bruce Diesel generator rooms will experience the same ]

environmental conditions and have the same  ;

expected life (138 years) as the 7032 relays. l i

' The fourteen (14) de-energized relays located in the Auxiliary Building will have an expected life of 226 years based on the Arrhenius Method.

I The two (2) continuously energized 7022 series relays are located in the Auxiliary Building.

They are relay numbers SFAD and SFBD and are in switchgear cubicles 4A00 and 4B03. These relays are part of the Safety Features Actuation System (SFAS) and remain energized during all modes of plant operation. To complete the analysis of these relays, the coil heat rise was taken into account when performing the expected life calculations. As a result, the two (2) 7022 series relays have expected lives of 10.85 years.

These relays.will be replaced at the Cycle 8 refueling outage under DCP 89-0020 and DCP 89-0021.

The justification for continuing to operate with these relays until the next refueling outage is as follows:

o The relays are located in a very mild environment for both normal operation and post-accident conditions. They are therefore not subject to common mode failure stresses.

o Each relay is used in a separate train of the SFAS, therefore, if a single random failure 1 occurs the SFAS will remain active through .

the redundant train. '

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o The relays are designed to operate with a-coil heat rise of 42 C and are capable of operating at full. coil wattage (8 watts),

o The relays.are tested for proper operation every refueling outage per SP.319A/B and every 2 years per EM.144.

The' ten (10) relays located in the NSEB will have an expected life of 201 years based on an environmental temperature of 800 F plus 180F cabinet heat rise.

The eight (8) ~ relays located on the roof of the Auxiliary Building will have an expected life of 114 0

years0 based on an environmental temperature of 90 F (+18 F cabinet heat rise).

4.9.5 Conclusions The fifty-four (54) commercial grade Agastat relays installed at Rancho Seco have been evaluated for Radiation Aging, Operational Cycling and Time / Temperature Effects. The radiation dosage and operation cycles'are well within the relay's design specifications. The expected life calculations demonstrate that fifty-two (52) of the 7000 series CG relays have. expected lives of over 114 years and can be considered qualified for.40 years. Two (2) 7022 series relays, which are continuously energized, will be replaced with Agastat E7022 series nuclear grade relays during the Cycle 8 refueling outage.

Conservative. engineering judgments were made as to the materials used to construct these relays. By determining that nylon is the limiting material, in conjunction with the mild environment and the length of the relay's expected lives, more than adequate margin has been demonstrated. This margin allows for minor deviations in the different formulations of nylon, as well as to envelope possible materials that can be substituted for nylon'in the construction of the 7012, 7014, 7022, 7024, and 7032 series CG relays.

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(fb 4.10 EVALUATION OF POTENTIALLY DEFICIENT FASTENERS a

I 4.10.1 Obiective I The objective of this task was to ensure compliance I with NRC Bulletin 87-02 through completion of all j actions as committed to in the 87-02 response to i establish acceptability of deficient fasteners- j installed at Rancho Seco.

l3 4.10.2 Scone

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NRC Compliance Bulletin 87-02 requested utilities to perform specific tasks for the purpose of determining whether fasteners in stores at nuclear facilities meet ]

j mechanical and chemical specification requirements. In response, SMUD tested 54 fasteiners from the warehouse. {

This resulted in the identification of one Quality i Class I and three non quality class stock codes where j the fasteners did not meet the specification j requirements. The District response to 87-02 {

transmitted the test results, as well as additional

• actions planned in accordance with 87-02, to the NRC on l January 20, 1988.

Engineering review of the test results determined the l

Class I fasteners acceptable for use. The deficient I test results were due to the test sample not meeting the minimum elongation requirement; however, since all design conditions at Rancho Seco lie in the elastic range for bolts, the deficiency (in the plastic range) posed no threat to plant safety. Additionally, the test sample passed the chemical, tensile strength, yield strength, and reduction of area test requirements.

4 The three non-quality class stock codes which produced i deficient fasteners were determined to require further i evaluation in order to establish acceptability.of installed applications in the plant and to ensure there has been no adverse impact to plant safety.

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4.10.3 Methodoloav and Results The engineering evaluation was performed in three steps. First, the out-of-specification conditions for each of the deficient. fastener samples were evaluated to determine generic acceptability criteria. The fastener deficiencies evaluated were due-to only minor deviations in the chemical specifications for chromium, molybdenum, nickle or carbon. No cases were identified where the fasteners failed to meet the specified teasile strength. This evaluation resulted in the establishment of the following use limitations:

1) For stock code number 026736: in cases where high carbon steel bolts have been used in lieu of high strength low allog steel bolts, the applications must be below 700 F to be acceptable without a detailed stress review.

2) For stock code numbers 024826 and 024821: in cases 3 where Grade 8 nuts have been used in lieu of Grade BM nuts, the application must be below 800 F to be acceptable without a detailed stress review.

Step two of the process was to review the installation histograms of the deficient fasteners against the  ;

i previously determined application limitations. The '

methodology utilized for this evaluation was to select the " worst case" representative examples from each stock code. Because the highest process fluid in the plant is 670 F the methodology used to identify the worst case applications was not determined to be critical. This temperature is below the established ,

evaluation criteria as well as below the maximum design temperature of the plant. For each deficient stock code, three worst case installed applications were selected, totalling nine initial sample review 4 candidates. The results of this evaluation would determine the necessity for a further look at additional fastener applications in the plant. j.

The appropriate installation documentation (ie., work requests, associated P&,'Os and vendor drawings) was j obtained for completion ( f the third and final step, the engineering review. A case-by-case review of the i nine specific applications was then performed. As shown by these results, the use of the fasteners in the reviewed applications are acceptable as installed and there is no demonstratable safety concern relative to 4 their use. Additionally, because of the pre-established acceptance criteria and the fact that the maximum I design temperature of the plant is 670 F, all other applications of these fasteners have been determined to be acceptable.

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4.10;4 Conclusions Based on the evaluation results, we have concluded that the fasteners. installed at Rancho Seco are acceptable-in their applications and do not' impact the operability of the plant.

4.11 QA SURVEILLANCE OF' PROJECT TASKS-

-The Quality Department was. charged with-conducting an audit of the-Procurement Program. The scope of this; routine' audit-was modified to include an evaluation of selected elements of the PEAP.-

Specific elements included in the audit were:

1. Assessment Plan' Phase 1 Report on Findings which reviews possible procurement impact on SMUD trips or transients.

2. The " Green Tag Validity check" verification program.

3. The District Commitment Item I.A Phase 2 which includes; a review of CGI replacement parts installed prior to the institution of the current " Dedication" program.

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The District Commitment Item III Phase 2 which includes a review of CGID Evaluations from September 1987'to

.present.

The results of this audit were documented in Audit Report ~

88-A-010. No significant-findings or observations were identified.

Additionally, the Quality Department has performed several surveillance on the PEAP. These surveillance are listed on Table 4.11-1. All findings and or observations have been defined and scheduled. With the exception oflthose identified on' Table 4.11-1, these findings have been closed out.

The work needed to close each item are complete. The open itemsLidentified in Table 4.11-1 will be closed upon final ,

j p surveillance by Quality Assurance. 1 l

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TABLE 4.11-1 QUALITY SURVEILLANCE ACCOMPLISHED AGAINST PROCUREMENT. PROJECT o

Surveillance No. Description Date Comp 88-S-114 . Green Tag Program 9/15/8 88-S-189 Procurement Impact on Reactor Trips / Transients /LER 3/14/8 88-S-200 Correct Procedure Cross-References 3/18/8 88-S-201 Clarify Handling of Damaged Materials 3/18/8 88-S-204 Clarify QA Action in Procurement Process 3/19/8 88-S-211 Complete Cable Qualification Testing 3/21/8 88-S-212 Clarify Level III Procurement Practices 3/22/8 88-S-220 Clarify Responsibilities of Procurement Program 3/21/8 88-S-225 Revise CGIDE Evaluation Procedures 3/24/8 .

88-S-227 'l Review Previous Level III Purchases 3/23/8 88-S-233 Generic Evaluations of Commercial Grade Items 3/25/8 88-S-330 Obtain~Part 21 Certifications - Bergen Patterson 5/4/88 88-S-408 Fasteners (IEB 87-02) Open 88-S-410 Ensure Validity of " Green Tag Program" 6/30/8 88-S-475 Stock Material Reverification 10/5/8 88-S-478 10CFR21 Evaluation 88-S-479 8/31/8 88-S-480 88-S-483 EQ Piece Part Evaluations Open 88-S-514 Like-for-Like CGID Evaluations Open  !

88-S-550 Reactor Trip Systems CGI Reverification Open l 88-S-556 CRD UVDs 10/28/

88-S-557 RPS/SFAS CG Relay SEQ Reverification Open 88-S-558 Agastat Relay Qualification (IEN 87-66) Open 89-S-027 RPS/SFAS/CRD Re-evaluation Open f 89-S-028 EQ Piece Parts Re-evaluation Open i 47

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5.0 CONCLUSION

S For the last two years, SMUD has been engaged in a comprehensive 1 effort to upgrade procurement and material control practices. As  !

noted in Section 4.0 of this report, extensive efforts have been made.to institute new and revised procedures. The result is an improved procedural program which provides effective controls'and clear direction to personnel involved in'the procurement and material control processes. A high level of management attention has been directed at this program, not just to meet minimum requirements but to excel in every facet. Program implementation has further been enhanced through the establishment and use of the Materials effectively control tracked and Action Plan to ensure that all actions are implemented.

Based on the results of the Phase 1 program and other related programs such as EASRTP and SRTP, SMUD considers that a high level of confidence in the suitability of installed equipment has been demonstrated. The comprehensive and in-depth evaluation of the issues involved in Phases 2 and 3 have shown that the safety function of Class I systems and components has not been degraded.

SMUD is'therefore assured that the goals for plant safety and operability have been achieved.

The results of Phases 2 and 3 oi the PEAP indicated that past procurement practices at Rancho seco were less stringent than those of today, especially in the area c commercial grade items.

These practices allowed the use of some items in Class I safety systems without thorough verification documentation to support such use. The thorough evaluations conducted in Phases 2 and 3 q

dealt to a large extent with reconstituting or obtaining the necessary documentation. However, out of the more than 3300 work requests identified / reviewed, only four items were demonstrated to be unsatisfactory and were replaced with qualified parts:

1) A high temperature ASCO Coil in the hydrogen monitor solenoid replaced a coil not meeting the temperature requirement. This case was determined, after review of all solenoid valves in EQ applications, to be isolated.

2) A power wire in the Hydrogen Monitor Cabinet Heater was determined to have unacceptable insulation for its application. This case has been isolated to this specific vendor.

3) Limitorque motor pinion gear key stocks. Review of 1572 MOV work requests identified only these tue inotances of the use of untraceable key stock. It is concluded that these are isolated instances.

With regard to evaluation of previously purchased Quality Class I material now in stock, results of these assessments provide confidence that current controls are effective in assuring that warehouse stock available for issue is adequately qualified.

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.y o f gfg, JJ ' *: 6.0 PREFERENCES ~

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1. . 1;RC Submittal, " Procurement Engineering Assessment Plan Interim Report",~ March 1, 1988.

2. NRC Submittal, " Procurement Engineering Assessment Plan Status Report", November 18, 1988.

3. NRC Submittal, " Procurement Engineering Assessment Plan.

Followup Status Report", December 22,'1988.

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ATTACHMENT 1' LISTING OF NCR/PDQs CENERATED DURING THE PEAP 10CFR50.49' HARDWARE NCR/PDQ IMPACT NUMBER _ __LLLEl___ DESCRIPTION NCR S-7772 Y. ASCO Colt in the hydrogen monitor solenold.

Dispositioned prior to restart by replacing the incorrect coil with a high temperature E'

Class H colt quellfled by the vendor in EAST Test Report 1035 1.

g NCR S 7775 -N Accelerometers and cables in the MSS acoustic monitors. Dispositioned prior to restart by removing the accelerometers'and cables from'the 10CFR50.49 list because they are not required to function in a post accident environment.

!L- NCR S-7788 Y Wiring in the hydrogen monitor cabinet heater.

Dispositioned prior to restart by replacing-the wire with 16 AWG BlW silicone wire.

.NCR S-7761 N Vendor supplying SCN 022981 was not on ASL at time of purchase. Dispositioned by information confirming vendor was qualified >

nuclear industry supp!!er. Acceptable per Bechtet Vendor audit.

NCR S 7769 N Insufficient documentation to' support the use-of SCN 002997 in seismic apptfemtions.

Dispositioned by SEQ review accepting as like-for like.

NCR S-7820 N Insufficient documentation to support the use of SCN 006529 in Class I applications.

Dispositioned by component evaluatior determining part does not perform a safety related function. Acceptable os is.

[ NCR S 7889 N SBN switch in diesel generator. Dispositioned (PDQ-86 0964) by evaluation determining that ne switch was capable of performing its function under worst case accident conditions.

PDQ 88-0016/ Y Traceability of Limitorque motor pinion key j PDQ 88 1155 replacement. Dispositioned by replacing the l pinion key with a fully qualified key.

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1. 1. 41 1 ATTACHMEhT 1,(Continued)

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LISTING OF NCR/PDQs GENERATED'DURjNG THE PEAP ty, l 10CFR50.49 l

HARDWARE WCR/PDQ. IMPACT NUMBER'_ _,

(Y/N) __, DESCRIPTION PDQ-88*0330 N Omission of applicabilf*y of the provisions of Part 21 on some purcha. orders for Class I items and/or services. Dispositioned by implementing Engineering Support Instruction ERT 07, seeking confirmation ' rom suppliers that they did impose Part 21 on Cissa I materlat c-supplied to SMUD.

3 f-PDQ 88-1273 N Traceability of Bonnet nuts on RBS check i valve. Dispositioned by initiating work request 140784 to replace these nuts with ASME nuts. I

, PDQ 88 1595 N Traceability of motor bearings, motor shaft tip seal, and torque switch. Currently in Material Control for disposition.

' PDQ 88 1427 N Insufficient documentation to determine method -

of procurement for parts installed. Currently l In Nuclear Engineering for final disposition.

l PDQ 88 1466 N Inconsistent I.D. number between transmitter installed in plant and that indicated in the work request. Also the use of Teflon 0-rings inside containment for flow transmitter.

Dispositioned by IRC as acceptable for I.D.

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number discrepancy. Also o ring will be changed to acceptable type. Currently in GE for sign-off.

PDQ 88 1101 Rev. 1 N Evaluation of potentistly deficient fasteners.

Currently in QE for sign off.

PDQ-A8 2028 Y Traceability of Limitorque motor pinion key replacement. Dispositioned by reptseing the  !

pinion key with a quotified key.

PDO 88 2030 N Four tork requests installed untraceable electronic components utilized in the RPS

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modules. These items were subsequently accepted based on the results of tech spec related surveltlance testing of the RPS.

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• p- -ATTACHMENT .1'(Continued)L LISTING OF NCR/PDQs GENERATED DURING THE.PEAP- l Ny o .

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'10CFR50.49 HARDWARE NCR/PDQ. ,

IMPACT NUNBER-' __

(Y/N) ,; DESCRIPTION PDQ 89 0025 -N lt'was determined that untraceable power supplies.were installed in the RPS. The 1 disposition of this PDQ est'ablished the power II

( .- supplies were'provided by. Babcockand Wilcox as QA Class 1. l

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