ML20245J051
| ML20245J051 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/14/1989 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Wilgus W FLORIDA POWER CORP. |
| Shared Package | |
| ML20245J054 | List: |
| References | |
| NUDOCS 8908170472 | |
| Download: ML20245J051 (6) | |
See also: IR 05000302/1989200
Text
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UNITED STATES
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NUCLEAR HEGULATORY COMMISSION
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WASHINGTON, D. C. 20556
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August 14, 1989
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Docket No. 50-302
Mr. W. S. Wilgus
Vice President, Nuclear Operations
Florida Power Corporation
Attn: Manager, Nuclear Operations
Licensing
Post Office Box 219-NA-21
Crystal River, Florida 32629
Dear Mr. Wilgus:
SUBJECT:
INSPECTION OF THE VENDOR INTERFACE AND PROCUREMENT PROGRAMS
AT THE CRYSTAL RIVER NUCLEAR PLANT UNIT 3, INSPECTION
REPORT NO. 50-302/89-200
This letter transmits the report of the inspection conducted A
May 5,1989, at the Crystal River Nuclear Plant, Unit 3 (CR3) pril 24 through
conducted by
Messrs. R. L. Pettis, K. R. Naidu, J. J. Petrosino, and S. M. Matthews of the
NRC Vendor Inspection Branch (VIB), and Messrs. E. Lea and R. W. Wright of NRC
Region II. The inspection was related to plant site activities authorized by
NRC License Number DPR-72. At the conclusion of the inspection our findings
were discussed with fir. E. E. Renfro, Director, Nuclear Operations Materials
and Controls, and the members of your staff identified in Appendix A of the
enclosed inspection report.
The purpose of the inspection was to review the implementation of the CR3
vendor interface program and the programs for the procurement of both
safety-related and commercial grace items currently installed in safety
applications at CR3. The results of the inspection indicate that deficie.rcies
exist in the areas of procurement ar.d dedication of comercial grade items and
interfaces between CR3 and its vendors.
The deficiencies include the failure
to properly dedicate and maintain documentation for commercial grade items
procured for use in safety-related applications, and the failure to impose on
venders the provisions of 10 CFR Part 21 when the purchase orders specify
requirements to nuclear specifications.
In particular, CR3 frequently failed
to perform documented technical evaluations to identify attributes such as the
components' safety functions and critical characteristics, verifications of
design and manufacturing / material changes, and receipt inspection requirements
beyond a part number verification and check for physical damage and cleanliness.
The inspection noted that this resulted in the utilization of numerous
components of unverified quality installed in safety-related applications at
CR3. As noted below, your subsequent review of the identified items indicated
that operability of equipment at CR3 has not been compromised.
The review of the CR3 vendor interface program indicates the need for
improvement, especially as related to timeliness, depth of assessment, and
implementation of follow-up actions of communications CR3 receives from the
NRC, Babcock & Wilcox, and vendors of key safety-relatec equipment, and the
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Mr. W. S. Wilgus
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AUG 14 m
We acknowledge the receipt of your letter, dated May 31, 1989, wherein you
described your plans for reviewing a representative sample of commercially
procured items installed in safety.related applications, similar to the
operability assessment performed for eight representative items identified by
NRC at the conclus4n of the inspection. This review is scheduled for
completion by December 31, 1989.
In addition, you stated that your review
of the remaining items b dicated operability of CR3 equipment had not been
compromised.
NRC will *eview your response and advise you accordingly.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
OriginalSigned by
Steven A. Varga, Director
Division of Reactor Projects I/II
Office of Nuclear Reactor Regulation
Enclosures:
1.
Potential Enforcement findings
2.
Inspection Report No. 50 302/89 200
with Appendices A and B
cc:
see next page
DISTRIBUTION
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August 14, 1989
evaluation and implementation of corrective actions on service and maintenance
recommendations received from the emergency (diesel generator manufacturer
Industries /Fairbanks Morse Engine Division FMED). Specifically, for example,
six SILs, dated June 22, 1987, received by CR3 were not placed into the
licensee's system for evaluation and tracking until April 6,1989.
The inspection findings discussed above and in the enclosed report have been
classified as Potential Enforcement Findings 50-302/89-200-01, 02, and 03
(Enclosure 1). These will be referred to the 14RC Region II office for appro-
priate action.
We acknowledge the receipt of your letter, dated May 31, 1989, wherein you
described your plans for reviewing a representative sample of commercially
procured items installed in safety-related applications, similar to the
operability assessment performed for eight representative items identified by
NRC at the conclusion of the inspection. This review is scheduled for
completion by December 31, 1989.
In addition, you stated that your review
of the remaining items indicated operability of CR3 equipment had not been
compromised.
NRC will review your response and advise you accordingly.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely, O
.
rg'a , h e - r
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Divisier cf Reacter Pr4 scts 1/11
Office of IAtlear React N Regulatior.
1.
Lotentirl Enforcement Findir.gs
2.
Iaspection Report No. 50-302/89-200
with Apcendices A eno 6
cc:
see next page
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Mr. W. S. Wilgus
Crystal River Nuclear Plant, Unit 3
Florida Power Corporation
cc:
Mr. A. H. Stephens
State Planning and Development
General Counsel
Clearinghouse
Florida Power Corporation
Office of Planning and Budget
MAC - A5D
Executive Office of the Governor
Post Office Box 14042
The Capitol Building
St. Petersburg, Florida 33733
Tallahassee, Florida 32301
Mr. P..F. McKee, Director
Chairnen
Nuclear Plant Operations
Board of County Commissioners
Florida Power Corporation
Citrus County
Post Office Box 219-NA-2C
110 North Apopka Avenue
Crystal River, Florida 32629
Inverness, Florida 32650
Mr. Robert S. Borsum
Mr. Rolf C. Widell, Director
Babcock & Wilcox'
Nuclear Operations Site Support
Nuclear Power. Generation Division
Florida Power Corporation
1700 Rockville Pike, Suite 525
Post Office Box 219-NA-21
Rockville, Maryland 20852
Crystal River, Florida 32629
Resident Inspector
- Mr. Gary L. Boldt
U.S. Nuclear Regulatory Connission
Vice President, Nuclear Production
15760 West Powerline Street
Florida Power Corporation
Crystal River, Florida 32629
Post Office Box 219-SA-2C
Crystal River, Florida 32629
Regional Administrator, Region II
U.S. Nuclear Regulatory Commission
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101 Marietta Street N. W., Suite 290C
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Atlanta, Georgia 30323
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Mr. Jacob Daniel Nash
Office of Radiation Control
'3
Department of 14ehlth and
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Rehabilitative Services
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1317 Wirewood Beuleverd
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Tallahassee, Florida 32399-0700
Administre tor
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Department of Enviroranental Requietion
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Power Plant Siting Section
State of Florida
2600 Blair Stone Road
Tallahassee. Fleiida 3230L
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee, Florida 32304
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Enclosure 1
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POTENTIAL ENFORCEMENT FINDINGS
Florida Power Corporation
Docket No. 50-302
Crystal River Nuclear Plant, Unit 3
License No. DPR-72
During the Period April 24 through May 5, 1989, representatives of the NRC's
Vendor Inspection Branch reviewed the vendor interface and procurement programs
of the Crystal River Nuclear Plant, Unit 3 (CR3). As a result of the inspection,
and in accordance with the " General Statement of Polic
Enforcement Actions," 10 CFR Part 2, Appendix C (1986)y and Procedures for NRC
, the NRC inspection team
identified the following potential enforcement findings:
A.
Potential Enforcement Finding 50-302/89-200-01
The NRC inspectors identified numerous examples of past and present
procurement activities where the licensee installed commercial grade
items (CGIs) in safety-related applications without adequately
evaluating their suitability for use in such applications. One
deficiency involved CGIs procured without performing adequate technical
evaluations to identify attributes such as the components'/ items'
safety functions, critical characteristics, and suitability as a
replacement in a seismically qualified system.
Instead, CR3 relied
primarily on a like-for-like substitution based on part number, catalog
specifications, or original purchase order requirements.
This rationale
is not adequate to verify that no design, material, or manufacturing
changes have occurred which could affect the item's ability to perform
its intended safety function under operational, seismic, design basis,
or environmental conditions.
This programmatic deficiency resulted in
numerous components of unverified quality being installed in
safety-related systems.
An additional procurement program deficiency concerns thu frilure nf CR3
to vclidate statements and/or certificates of conformance (CDC) re:.eived
and accepted from vencors not on the CR3 Approved Nuclear Suppliers List
(ANSL) for the type of procurement specified or not formally surveyed to
establish a firm technical basis for reliance on such certification.
Commercial suppliers furnisning iteres to CR3 for eventuti use in
safety-related applications were, in some cases,
lared on the ANSL du
to their having a 30 CTR Part 50, Appendix B, gnagity assurance (QA)
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program.
In other casa, nppliers were placed on the ANSL based on
staterrents by sources external to CR3 that the vendor has an acceptaole
program for a particular type nf procurement.
The primary basis for
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inclusinn and nintencnce of a comercial vendor on the ANSL was limited
to a C23 " desk" rei few of the vendor's QA program manual. This practice
of approving vendcr! and accepting invalidated statements and/or C0Cs, is
not an acceptable method of establishing the similarity of items used in
safety-related applications.
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Florida Power Corporation
Docket No.
50-302
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Crystal River Nuclear Plant, Unit 3
. License No.
The examples identified by the inspectors are detailed in Section 1.1
of the inspection report.
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B.
Potential Enforcement Finding 50-302/89-200-02
The NRC_ inspectors identified that procurement made to the Vitro
Corporation and Dubose Steel, Incorporated, for safety-related material
which specified requirements unique to nuclear specifications, failed to
a
invoke the provisions of 10 CFR Part 21.
C.
Potential Enforcement Finding 50-302/89-200-03
The NRC inspectors determined that the licensee failed to comply with
CR3 Procedure. AI-404, " Review of Technical Information, Revision 6, dated
January 31, 1989," for the evaluation and implementation of recommended
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actions given in service information letters (SILs) received from the
emergency diesel generator (EDG) manufacturer, Colt Industries /Fairbanks
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Norse Engine Division (FMED).- In most cases, the SILs were not evaluated
properly or in a timely manner for their applicability to CR3.
In partic-
ular six SILs, dated June 22, 1987, were received by CR3 but were not'
placed into their system for evaluation and tracking until April 6,1989.
Furthermore, appropriate corrective actions to implement recommendations
identified by CR3 and revisions to the governing maintenance and operation
manuals and procedures for the 1A and IB EDGs were not always performed.
Two examples are discussed in Section 3.4.3.
The NRC inspectors also identified several NRC and vendor communications
describing potential Safety concerns that were received at CR3 but were
improperly ard/or incompletely assessed for their applicability. The
depth of the documented technical evaluations in many cases was at a
level that dic ret justify CR3's basis for disposition.
The examples
identified by the inspectors are listed in Section 3.2 ef the inspection
a
report.
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