ML20245J058
| ML20245J058 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/04/1989 |
| From: | Brach E, Robert Pettis Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245J054 | List: |
| References | |
| 50-302-89-200, IEB-88-010, IEB-88-011, IEB-88-10, IEB-88-11, IEIN-88-080, IEIN-88-80, NUDOCS 8908170477 | |
| Download: ML20245J058 (29) | |
See also: IR 05000302/1989200
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N Enclosure 2
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INSPECTION REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
DIVISION OF REACTOR INSPECTION AND SAFEGUARDS
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Report No.: _'50-302/89-200
Docket No.: 50-302
Licensee:' Florida Power Corporation
Post' Office Box 14042
St. Petersburg, Florida 33733
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- Facility Name: Crystal River Nuclear Plant, Unit 3
Inspection At: Crystal River, Florida
Inspection Conducted: April 24 through May 5,1989
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Inspectors:
b ?5
Robert L. Pettis, Jr., TearrfLeader Dat~e
Vendor Inspection Branch (VIB)
K. R. Naidu, Sr. Reactor Engineer, VIB
'J. J. Petrosino, Quality Assurance Specialist, VIB
S. N. Matthews, Quality Assurance Specialist, VIB
E. Lea, Reactor Inspecter, Rll
- _ R. W. Wright, Reacter Inspector, RII
Consultants: P. R. Farron, Fuclear Energy Consul +crts, Inc.
F. C. Webb,ficclear Energy Consulttots, Ir.t..
Approved By:
L WiMiam Bra
g t 5 /!)f
f )
7"CMof Date
p Vendor Inspection Branch
Division of Reactor Inspection and Safeguards {
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8908170477 890814 I
PDR ADOCK 05000302 l
Q PDC
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Inspection Sumary
Inspection Conducted from April 24 - May 5, 1989 (Report No. 50-302/89-200)
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Areas Inspected: A special, announced inspection was conducted by the Vendor
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Inspection Branch to review the implementation of the licensee's vendor interface
program and the program for the procurement of items for use in safety-related
applications at the Crystal River Nuclear Plant, Unit 3 (CR3). The inspection
l team reviewed the documentation of specific vendor-related technical issues,
including 10 CFR Part 21 notifications received at CR3, and the documentation
concerning the procurement of safety-related installed equipment, including
molded-case circuit breakers.
4
Results: The Nuclear Regulatory Commission (NRC) inspection team identified
the weaknesses discussed below in the CR3 procurement program and the interfaces
between the licensee and its vendors.
(1) Numerous instances were identified where the licensee installed commercial
grade items (CGIs) in safety-related systems without adequately evaluating
their suitability for use in such applications. Verification of design and
manufacturing / material changes, safety functions, critical characteristics,
or receipt inspection requirements beyond a part number verification, and
check for physical damage was not performed. The licensee also upgraded
nonsafety-related items to safety-related through the material qualifi-
cation form (MQF) process, in which traceability to the original manufacture.r
could not be ce ablished.
(2) The NRC inspectors identified several instances in which the licensee
failed to specify the
purchase orders (P0s) for provisions of 10 CFR
items intended forPart
use21 in as being applicable
safety-related on
appli-
cations, that specified that the components or items purchased must be in
accordance with nuclear specification or quality assurance requirements.
Such procurement were not consistent with the definition of comrrercial
grade items ir. 10 CFR 21.3 ard thus the ptocurements should have specified
the 6 applicability of 10 CFE f art 21 or. nuclear safety-related procurerr.ert
docurren t s .
(3) "he hRC inspectu e. 1dentified th6t befcre the inspectier., the licensee had
nut established a forrial program for the receipt, evebation, one implemen- i
tation ct recomenced corrective actions for incomir4 technic ' information
to CR'.
! As a resnit, e rtain service information letters (31Ls) receivea
from the emergency dicsel geterator manuf acturer did rot receive a cocurnen-
ted saluttion for their applicability to CR3. In addition, information '
contained in the technical manuals and SILs was not being used to evaluate
results from inspections and tests perforred on the diesels. Two examples
are discussed in Settina 3.4.3.
Thfe NRC inspectors also identified several vendor communications describing
potential safety concerns that were received at CR3 but were improperly
and/or incompletely assessed for their applicability to CR3.
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l Conclusion
The procurement and vendor interface program deficiencies identified have been
classified as Potential Enforcement Findings 50-302/89-200-01, 02, and 03.
These findings will be referred to the NRC Region II office for appropriate j
action. 1
1. PROCUREMENT
The NRC inspection team reviewed the programs for the procurement of services {
and parts, components, and equipment currently installed in safety-related j
applications at CR3. This review addressed the procedures that govern the i
procurement process, as well as the methods used to upgrade (dedicate) commercial l
grade items (CGIs) for use in safety-related applications. A program description {
and the results of the review of the CR3 procurement procedures are contained 2
in Appendix B of this report. To evaluate the implementation of the program,
the NRC inspectors reviewed selected CR3 procurement of items installed in
safety-related systems that were procured both as connercial grade and as
safety-related from approved suppliers having a 10 CFR Part 50, Appendix B,
quality assurance (QA) program. In addition, the inspectors also reviewed
CR3's program to dedicate items originally purchased as nonsafety under CR3's
Material Qualification Form (HQF) process.
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1.1 Procurement Package Review
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To evaluate the procurement of services and replacement piece-parts,
- components, and equipment for use in safety-related systems, the inspectors
reviewed purchases made under the CR3 system during the 5 years preceding the
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inspection in the following areas:
L upgrading nonsafety material to safety-related under the MQF process
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spre and replacement parts procured both as safety-related and as commercial
l grade es r ecorded in CR3's fully integratec raterials information, system ,
j (FIMIS) {
safety-related procurement that supported modifiutions made curing the Ir.st
two refueling cutaces
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safety-re16ted prccurements obtained frcm other nuclear utilitir.s rither j
dit ectly or through material brokers 1
upgrading of molded-case circuit breakers identified through CR3's response
L Additionally, the inspectors reviewed mintenance work rmuts for
i safcty-related systems to identify maintenance activities that
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required the use of replacement parts. From these reviews, the inspectors
identified numerous components that had been installed in safety-related
systems and those that had been placed in inventory for future use in safety-
relateo applications. The inspectors then revieweo the record packages for
these specific component procurement. The review concentrated on the three
key criteria given below to determire 4f the component selection, procurement,
receipt, and dedication process (CGIs only) were appropriate for the circumstances.
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Were appropriate measures implemented to meet 10 CFR Part
50, Appendix B, Criterion III requirements for selection and
review for suitability of application of materials, parts,
equipment, and processes that are essential to the safety-related
functions of systems, components, and structures?
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Were appropriate measures implemented to meet 10 CFR Part 50, Appendix B,
Criterion VII requirements for ensuring that equipment conforms to the
procurement documents, with appropriate provisions to ensure that objec-
tive evidence of quality is furnished to the licensee and evidence
produced by licensee actions, such as examination of products upon
delivery, are maintained to document that the requirements and specifica-
tions are met?
Were the requirements of 10 CFR Part 21 imposed in procurement documents
when required for manufacturers / suppliers to ensure as a minimum that
nonconformances or failures to comply with requirements would be reported
to the licensee so that the licensee could evaluated such deviations in
accordance with 10 CFR 21.21?
The NRC inspectors reviewed approximately 150 procurement packages to determine
if each procurement was performed properly and to evaluate the overall
effectiveness of the CR3 procurement program. On the basis of their review
of these packages, the inspectors found numerous instances of improper
commercial grade dedications with inadequate or nonexistent supporting
documentation (testing, analysis, or inspection data) to ensure the CGIs were
suitable for the intended applications. Specific examples of components
purchased safety-related, commercial grade, or nonsafety, and subsequently
installed in safety-related applications follow:
(1) The examples listed below are of safety-related purchase orders
(P0s) for which the licensee failed to impose the requirements of 10 CFR
Part 21 on the supplier because the procurement was inappropriately
classified as meeting the definition of commercial crace. These
procurement referencec ncclear specifications that had been
referer.ced in the original equipment procurement, therefore they I
could net rceet the oefinition of cornercial grade as defined by 10 CFR
21Q(a-1;
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PCs F9024437K ano F9055078K - Issued to Vitro Corporation f:x {
replacement electronic trip modules used in the emer gency feedwuter j
initiation and control (EFIC) systen that were procured as safety-
related. The orginal Babcock & Wilcox specificatict., referenced in {j
the procuresnent document, specified conformance to the requitanents
of the Institute of Electrical and Electronics Engineers (IEEO code l
and ttendard IEEE 323-1974, " Standard for QuaMfying of Class 1E !
Equipment for Nuc? ear Fower Generatirg Stations."
P0s F9056597C and F9059680C - Issued to Debose '.iteel for piping
elbews used in the service water system which were required to be
supplied in accordance with their ASME Section III, NCA-3800 Quality
Assurance program.
(2) The examples listed below were purchased as cc mercial grade and installed
in safety-related applications without an adecuote cecication performed. 1
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These examples were discussed with licensee representatives during the
inspection. The licensee was requested to address each item because there
was no documentation to verify suitability for application, safety functions,
and critical characteristics beyond. that which is inherent in the part
number description shown in the manufacturer's catalog. Because of the
number of items identified, the licensee was unable to adequately addre'ss
each issue before the conclusion of the inspection. .Therefore,.during the
exit meeting, the NRC staff requested the licensee to participate in a
management meeting to discuss the issue of operability before the restart i
of CR3 for several key items. This meeting was held on May 12, 1989, at
the NRC Region II offices. During this meeting, the licensee demonstrated
general operability'of these items through post-installation and periodic
maintenance testing. Purchase orders representing these key issues are
identified by an asterisk in the list of examples given below.
- P0 F9041437D - Issued to Nuclear Installation Service (NIS) on
February 4,1986, for the repair of a link bar (rigid strut assembly)
for seismic support of the reactor coolant pump. Although NIS had
beenplacedonCH3'sApprovedNuclearSuppliers' List (ANSL).in
January 1986, because it had an ASME NA & NPT certification, it was
subsequently removed from the ANSL in 1987. The inspectors noted i
that a review of NIS's QA manual was not performed as required by
Section 7.1.3.3 of the CR3 Nuclear Procurement and Storage Manual
(NPSM). The P0 did not impose the requirements of 10 CFR Part 21
on the repair, but categorized the work as safety-related. The
inspectors noted the licensee had developed a source inspection plan
for the repair, however, documentation was not available to demon-
strate that the inspection was performed. The receipt inspection
plan covered only a visual inspection of the part number and a check
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for physical damage. No inspection was performed to verify thread
engagement in the vicinity of the repaired area or structural load
capacity of the assembly. Additionally, from the documentation in
the P0 package, it appeared that tilS subcontracted the repair work to
d subvender, Pioneer iMchinery, with the authority tu replace
components as r.ecessary. There were no material certifications:or !
repair stancat ds in the package tc cetermine the extent of work that >
was actudlly performed.
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'. *PO F9C43160C - Four hancred 7/6-inch heavy Lex nuts, /.STM Grade C, n re j
rutchased from Bolt Industries tor ute in nonpressure-retaining applications. j
Receipt inspection was performed in eccordance with Section 8.4.3 oi the j
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CR3 NPSM and receipt inspection plan ho. 121. As a result, the nut 3 were
found satisfactory and releastd f or use. On April 2, 1989, a-crack was
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visually identified in a nut being prepared for painting. A dye penetrant ;
test was performed ant' fndicated the crack extended through the wrenching j
w rface of the rut. The one nut was returned because it did not comply
With CR3 Procedure MP-139A ed a quality materials problem report was
written. At the time of the WRC inspection the licensee had not determined {
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the application of the remaining nuts, however, work requests indicated ;
possible use on the reactor coolant pumps. Twenty nuts were used on the 1
moisture separator reheater lifting beam, while the rest of the nuts were I
held in the warehouse pending further dispos 1 tion. No further testing was
performed or. any of the nuts. {
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The following P0s were for safety-related items procured as commercial I
grade from the original equipment manufacturer, Colt Industries, with one
exception, without an adequate dedication. Dedication was limited generally
to a part number verification and receipt inspection, which included a
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' check of cleanliness and physical damage. Theer. items were installed in .
.the 1A and IB emergency diesel generators (EDGs).
- PO F9032244K for an aluminum main bearing shell assembly
P0 F9024863K for a blower assembly
. PO F840247K for jacket elbow insulation
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P0 F9042129K issued to Square D Company for a class 9012,
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Type ACW-9, Pressure Switch '
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l P0 205480K for manifold exhaust bolts
P0 F9038125V - Issued to Norton Corrosion Limited for an extended
snout, 9-inch shielded Bayanode element used for cathodic protection
and installed in the service water system. A review of the pro-
curement file revealed the following deficiencies: Hardness testing
upon receipt was required in the CR3 receipt inspection plan but
was not addressed in the verification plan and consequently was r.ot
performed; electrical characteristics were not addressed;
traceability was not established from the material manufacturer's
certificate to that of the Bayanode's manufacturer's certificate;
and a review for suitability of critical operating requirements
was not performed.
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P0
(3rdF9051657K - Issued
stage seal) for to Babcock
the reactor & Wilcox
coolant pur.ips for. a body) rotating face
(RCPs
P0 F9041836K - Issued to Bebcock & Wilcox for a seal package holder
spring for the RCPs.
- P0 F902893K - Issued to Woodward Governor Company f or a gcvernor,
Mocel No. 9903-224 US, S/N 0286575, that was procured commerci*)
grade and installec on the No.1 emergency fee &ater -pump. Dedication
was limited to a part number verification in an attemot to verify
cq;ivalency te the original governor installed. The licensec did not
verify with Woodward that no naterial or design changes had occurred
since the original procurement nor did it receive, as reouested by
the original P0, certification stating thet tne subject replacement
governor met or exceeded requirernents imposed or: original Test
Specification No. 494. The receipt inspection was limited to identi-
fication and marking, physical damage, and cleanliness. Seismic
performance and mounting configuration were not addressed by the
licensee because it believed this was a like-for-like replacement
and, as such, would not require any evaluation.
P0 F9060133V - Issued to Abbott Associates for a 5-inch duo-check
valve installed on the IB EDG. Nuclear engineering's specific
instructions, as contained in CR3's safety-related procurement
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checklist form, specified an alloy separator test of the valves
to confirm the material's conformance to manufacturer's catalog
No. 310-4. The applicable receipt inspection plan did not
incorporate this instruction; consequently the test was not
performed. Inspection was limited to identification and marking,
physical damage, and dimensions.
PO F9021925K - Issued to York Corporation for a model HT-230
purge unit compressor that was installed in the chilled water
system. A review of the procurement records identified the
following deficiencies: no receipt inspection plan was provided;
critical characteristics and safety function were not identified;
and no basis existed for the licensee to accept a certificate of
compliance from the vendor. York was approved as a safety-related
commercial supplier because it had an ASME Section VIII program
that covered pressure vessels; however this appeared not to be
related to the manufacture of a purge u, nit compressor. In addition,
Section VIII requirements are not equivalent to those required for
items in safety-related applications.
PO FF17817V - Issued to W. R. Ladewig Company for a 200-pound-per-square-inch
spring, manufactured by C. and M. Spring Engineering Company, used .in a '
i-inch Texsteam pressure relief valve that was installed in the decay heat
closed cycle cooling system. A review of the procurement package revealed
the following deficiencies: &
a. The package did not contain a specification, certified functional
test report from the vendor, or a configuration certificate.
b. The material certificate of compliance from the supplier was not
traceable to the spring manufacturer's certification, which in turn
was not traceable to the materiel nanuf acturer's certified material
test report.
c. The basis for W. R. Ladewig to certify thtt items supplied
dTE Equal t0 Dr sUferior to dnd interch3nf;etble with Texsteam
valve ; arts was rct evident.
d. The licensee's verification plan ider.tified procedure l'.P-119
as the basis and crittria for a fw ctfenal characteristic test;
however, HP-119 does not accress the full-lift or blow-down
requirements, the test mecium differential between air over
water, or thc service condition,
e. A letter dated h ne 24, 1983, from W. R. Ladewig to the
licensee states that the springs are to be cFecked by Charles
Karrh. However, this was not evidtr.t from the NRC inspector's
review of the psckage,
f. The parts were procured for a Texsteam Figure 3152-2 pressure
relief valve. However, the site functional test to verify
characteristics for fit, operability, and reliability verified
performance using a type 1452-5 pressure relief valve.
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The following are examples of items purchased nonsafety, upgraded, and
installed in safety-related applications without an adequate dedication
performed utilizing the MQF process. Since this process upgrades items
initially purchased for nonsafety applications, procurement records
pertinent to each purchase have not been maintained
abilitytotheoriginalequipmentmanufacturer(OEM}therefore, trace-
is not possible.
This deficiency introduces the potential for the licensee to receive
misrepresented items / components from sources other than the OEM, which is
discussed in NRC Bulletin 68-10. " Nonconforming Molded-Case Circuit
Breakers," issued November 22, 1988. Another deficiency existing within
the MQF process, as identified by the NRC inspectors, is dedicating an
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MQF component or replacement part when the licensee is unable to obtain
certification from the supplier that no design manufacturing or material
changes have occurred. Without such assurance, certification of the
components ability to meet all design and operating conditions, including
seismic, is doubtful. Attributes such as the components' safety function
and critical characteristics were not documented in this process. Dedi-
cation primarily consisted of a part number verification of the replace-
ment item to determine equivalency. Documentation was not available to
support the items' seismic qualification.
MQF 1436-89 - Transferred three ASCO series 8321, three-way, air-operated
solenoid valves, initially procured as nonsafety, from the CR4 fossil
plant to CR3. These valves were installed in valves CAV-6-SV and CAV-7-SV
in the chemical addition system. The basis for dedication was limited to
a visual inspection, part number comparison with page 48 of ASCO's conser-
cial grade catalog No. 31, and a continuity check of the solenoids electrical-
coil.
MQF 1433-89 - Upgraded two series 8321 and two HT 8320A20 three-way
air-uperated ASCO solenoid valves. The electrical coils from the
8320 series valves were installed in the 8321 series valves that
were subsequently installed in raain steam valves MSV 130 and 138.
The dedication basis for the four ASCO valves was limited to a visual
inspection and a part rurter compat ison to that in the ASCO connercial
grade catalog.
MQF 142C-83 - Up;rodea 24 SB11AR, 5-amp, 125-volt pressore switches i
end TG30-A3? pre type transducers, brth tvanuf achred by A$CO. Charac. 1
teristic verification was limited to a visual check to demonstrate
that the components were not ohysically camaged and that the nameplate
details on the components matched these on the MQF. Verification
results indicated that all 24 witches were acceptable. ASCO
implements an Appendir B quality assur4nce progran during the manu-
facture of items procured as safety-related. However, items ordered
to comercial grade requirements do not benefit frca this program and
have bcen previously reported by NRC (Information Notice 87-66) to 3
have unacceptable performance for safety-related applications.
- MQF 1413-88 - Upgraded two Agastat 7012 ac model time delay relays. !
Characteristic verification was limited to a visual check of the 1
physical dimensicr.s per the Agastat catalog and of physical damage
and a verificatnn of nameplate details, such as voltace and time
range. CR3 Work Request 106190 documented the bench tests performed
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on'the relays to set the time delay to 10.02 and 10.07 seconds. The-
relays were installed. in ' A' and 'B' control rod drive breaker
cabinets in the "K-6" position. The seismic performance of the
relays used in this application and the certification to the original
configuration were not demonstrated by the licensee. In addition,
Agastat does not recommend this model relay for nuclear Class IE
applications.
MQF 1346-88 - Upgraded a Curtis Model RS-8 relay socket assembly
installed in the "K-7" position of the shunt trip assembly used in
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the reactor trip breaker control circuit. Dedication was limited
to checking the dimensions and configuration with that in the Curtis
catalog and a part number verification. Seismic performance was not '
verified because the licensee believed that a like-for-like
replacement was used.
MQF 1345-88 - Upgraded a Potter & Brumfield KRP 11 DG 24-volt dc
(Vdc) relay used in the "K-7" position of the shunt trip assembly of
the reactor trip breaker control circuit. The characteristics
verification was limited to a visual check of the relay and a
dimensional check against the catalog. Inspection for part number,
physical damage, and a verification that the relay is rated for 24 ,
Vdc were performed. The results of the evaluation indicated that the J
relay was acceptable and was tagged " Mild Environment Use." No
electrical bench tests were performed to energize the relay and .-
verify change of state of contacts before installation. In addition,
seismic performance of the relay was not verified.
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MQF 1341-88 - Upgraded a 600 volt, three-phase, 100-ampere ITE
molded-case circuit breaker, model HE 3A100, used in motor control
cer.ter 3Al to control operation of spent fuel pool pump 1A . The
characteristic verification was limited to a visual inspection to
compare the dimensicos with those listed in the catalog, to check for
physical damage, and to verify nameplate detailt.. There was r.o !
evider.te that the pump would provide the recessary flow rates, in
addition, no testing was performed to verify the seisniic performance
of tre breaker and the overall qualification of the pareat compcnent.
MQF 1332-88 'Jpgraded a 600 volt, three-pbase,10-ampere, hE 3A010-type,
ITF. molded-cese circuit bretker installed in connection with valve
MOV-53, located in the nakeup system. Characteristic verification
was lituited to a visual inspection to verify the dimensions and part
r. umber and to check for physical dange.
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HQF 1301-87 - Upgraded a three-phase HE 3A025-type ITE molded-care l
circait breaker requireo to replace a failed breakor nn meter cor.tro!
center 3B1 (unit 11D), which powered a notor-operated salve located
in the decay heat removal system. The characteristic verification
was limited to checking the dimensions and part number.
MQF 1228-87 - Upgraded a Potter & Brumfield relay that was installed
in the decay heat removal system. Dedication was limited to a visual
inspection to determine part number and overall configuration with
the manufacturer's catalog.
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- MQF 1084-86 - Upgraded a single-phase, 70-ampere EH IB070-type ITE
nolded-case circuit breaker that was installed in the distribution
-panel feeding the vital plant security system. The characteristic
verification was limited to a visual inspection of the configuration
with the ITE catalog, verification of part number, and physical
damage.
MQF 972-85 - Upgraded three Model VIIHAA three-way air-operated
solenoid valves, manufactured by Johnson Controls, for use in the air
damper system for the IB EDG. Dedication was limited to a visual
inspection to determine equivalency with the manufacturer's catalog.
MQF 954-85 - Upgraded a Limitorque Model SMB-C actuator assembly
purchased from the Harold Faust Company and installed in the reactor
building spray inlet valve, BSV-3. Dedication was limited to a
visual inspection to verify configuration with that on pages 21-24 of
Limitorque Catalog SMBI-82C.
MQF940-85-UpgradedfourASCOair-operatedsolenoidvalves(Part
No. HT 8321A8) that were installed on service water valves SWV-353
and SWV-354. Dedication was limited to a visual inspection with the-
ASCO connercial grade catalog to ensure equivalency. As pointed out
previously, ASCO manufactures a safety-related item for Class 1E
applications and a commercial grade item, both in the 8300 Model
series. The safety-related model number is prefixed by the desig-
nation NP (e.g., NP8329) and is the only solenoid valve. recommended
and qualified by ASCO for nuclear use.
1.2 Review of the Licensee's Response To NRC Bulletin 88-10
The licensee responded to NRC Bulletin 88-10, " Nonconforming Molded Case
Circuit Breakers," by letter 3F0380-10 dated March 7, 1989. The licensee
determineo that the 94 breakers stored in the warehouse were intended for
installation in safety-related systems. The licensee reported to NRC that
its review of the procuren,ent docursents showed 70 of the 94 breakers were
ucceable to the original manufacturer. Procurement docurrcr.ts for the
remainirg 24 brea'erst were not weilable. As c. result, a material prcblem
report (MPR), dated December 26, 1988, was generated by the licensee to
identify the lack of traceability to the original pianufacturer. The MPR
reconnended that the 24 braakers be sent tc the current manufacturer of
ITE breakers, Siemens Energy and Automation, Wilmington, North Carolina,
for inspection and confirmation that they were genuine ITE breakers and
that they had not been tampered with. The licensee issued P0 F740081A to
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the Hughes Supply Company, St. Petersburg, F?orida, to authorize Siemens
to inspect the breakers and determir,e if they were manufactured by any of 4
the ITE companiv.s and if there was any evidence of refurbishment. Twenty-
four breakers were shipped to Siemens as indicat?d by CR3 shipping manifest ..
i No. 293 0073, dated January 23, 1989. In a letter dated february 28, 1989,
Siemens stated that the CR3 breakers were inspected by quality engineers vno
determined that the breakers in question were manufactured by ITE and exhibited
no signs of alteration by an outside party.
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!During this inspection, the NRC ins)ectors examined 23 breakers returned
'by Siemens to CR3. Twenty-one of t1ese had labels to denote that they-
were manufactured by ITE Imperial, the original manufacturer or.ITE Gould,
the first successor to ITE Imperial. The remaining two breakers, HE 3A025-
' type, had current Siemens Energy and Automation labels.. These two breakers
appeared to be new with a manufacturing date code of March'1989. A visual
examination of the remaining 21 breakers revealed that they were affixed
with an inspection label to indicate that Siemens tested the breakers.
However, since the verification of 3roduct acceptability on these 21
breakers was performed without the >enefit of a Siemens documented quality
assurance program, the licensee intends to downgrade the items to nonsafety.
The NRC inspectors selected.5 of_ the 70 breakers that were. traceable to
P0s placed with the Square D Company. Visual examination of the Square D
and Underwriters Laboratories labels indicated that they were original and
were not misrepresented or tampered with and were all in the original-
' cartons furnished by Square D.
1.3 ' Upgrading of Commercial Grade Molded-Case Circuit Breakers
The licensee used the MQF process to upgrade comercial grade components,
including molded-case circuit breakers. An HQF was issued as a result of
a work' request that may have identified an inoperable component and that
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documents the installation. The MQF references a component in the warehouse,
originally purchased as nonsafety and with no procurement documents at hand,-
and outlines characteristics to be verified to dedicate the item and subse-
quently install-it in a safety-related application. The results of the
evaluation are also documented on the MQF. The licensee used a quality
control issue form to obtain the breaker from the warehouse. Post-
maintenance tests were conducted, in some cases, to verify the function of
the component installed.
The inspectors reviewed several MQFs, which indicated that electrical bench
tests were not performed to verify selected critical characteristics before the
installation of the breakers. As a miniciurt, (1) the electrical characteristics,
such as the ability of the breaker to close at the ratec current and voltage
for a specific tis:.e, (2) the brer.ker response to at.least one instantaneous
overloac value on the manufacturer's published curve, ano (3) the breaker
coordination requirements (as applicable) should have been verified. Additional
tens that should e.lso have been addressed include mognetic trip calibration,
trip functionality, contact resistance, insulation resinance, and a thermal
trip test, but were not performed as p&rt of the overall dedication process.
As t,tated previously, traceability to the original equipment manufacturer
cannot be established using the MQF approach.
.
i
2. @ALITY ASSURANCE AUDITS
The inspectort reviewed the licensee's Procurement and Materials Quality Assurance ,
Program for the evaluation and control of supplier quality performance for safety- '
related materials, equipment, and services. The procurement and materials quality
assurance group onsite has responsibility for the vendor evaluations. Suppliers
of safety-related items or services that are particular to the nuclear industry
are required to implement a quality assurance (QA) program in accordance with
10 CFR Part 50, Appendix B, and ANSI N45.2, as applicable to the scope of work
1
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performed.-- The licensee ensures the capability of suppliers of safety-related
items through performing periodic quality program evaluations (to establish
initial qualification and adequacy of supplier changes thereafter) and by
assessing the quality of . items or services through . inspection and surveillance.
Qualification of supplier's QA programs may also be established by the results
such as other nuclear utilities
of evaluations
or.the American conducted by other organizations,(ASME).
Society of Mechanical Engineers Commercial suppliers. y
,
'that provide items or' services not unique to the nuclear industry are evaluated. '
to ensure adequate control of their commercially available product. The
results of. supplier quality program evaluations are documented and status of'
suppliers is maintained on the approved nuclear suppliers list (ANSL).
2.1 Review of Safety-Related Supplier Evaluations
i
FPC evaluations of safety-related suppliers consist essentially of four
niements: (1)accumulationofapplicableevaluationdata,(2)reviewof
L nuclear evaluations performed by others, (3) review of the supplier's QA .
'
manual, and (4) establishing the need for_a . supplier's facility audit.- Several
sources of supplier data are used to accumulate the necessary information for
evaluation. Questionnaires, information requests, and quality program
update requests are distributed to suppliers as necessary or appropriate for
the product or service to be supplied. Procedures are requested for review
as well as (or in place of) the supplier's quality assurance manual. A copy .
of any ASME certificate, if applicable, also is requested. The licensee's :
staff may be requested to provide information on the basis of their personalE
experience with'the item or service. The supplier also is requested to provide
an audit report from an accredited industry source (e.g., Coordinating Agency
for Supplier Evaluation (CASE), holders of ASME certificates of authorization,
NRC-licensed utilities, and CR3-approved contractors). If there is insufficient
information to indicate satisfactory compliance with applicable requirements
from the above mentioned sources, the supplier's QA manual is reviewed for
inclusion of controls to assure compliance with all QA requirements applicable
to the item or service requested.
A facility audit of the supplier 's QA manual is not. required when any one of
the following cerditions exist:
A satisfactory audit of the supplier's CA prograra was conducted in the
past 3 years and evidence of this audit may be provided by industry
sources such as those listed above. )
{
The latest index of companies holding an ASME Section III certificate of i
authorization identifies that the supplier has been evaluate.d and approved i
for the same or similar raclear item or service within the past 3 years. )i
Other accredited nuclear. references have confirmed (by a facility aucit in !
the pust 3 years) the effective implementation of the supplier's QA 1
manual.
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ASME quality Section III, Paragraph
systems NCA-3800,)
certificate Material on
(QSC are evaluated Suppliers
the basis holding
of valid
their 0A manual, including a description for the positive identification
of material and the cualificatior, of material manufacturers. ASME QSC
certificate holders are also qualified to supply ronCode, sefety-related
items bcsed on the ASME occrec1tation.
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Suppliers approved for safety-related items also shall be evaluated for
the supply of commercial grade items.
It should be noted that with respect to the above, NRC Information Notice (IN)
86-21, " Recognition of American Society of Mechnical Engineers (ASME) Accreditation
Program for N Stamp Holders," dated March 31, 1986, recognizes that if ASME has
surveyed the supplier and issued a certificate of authorization of appropriate
scope, the licensee may place the supplier on their approved. suppliers list
without performing any additional evaluation of the supplier's QA program.
However, this recognition applies only to the prograunatic aspects of the ASME
Accreditation Program and licensees are still responsible for ensuring that its
supplier is effectively implementing its approved QA program. The licensee's
interpretation is not consistent with the IN.
2.2 Implementation Review
The inspection reviewed eight safety-related supplier evaluation packages,
relating to the safety-related nuclear procurement reviewed during the
inspection. This review revealed that seven of these suppliers were placed on
the ANSL on the basis of a facility audit performed by other than CR3 personnel.
Procurement were subsequently made without evidence that the licensee had i
performed a facility implementation audit of the suppliers' quality program ;
before issuing the purchase order. A description of these vendors and '
associated issues are given below. '
Vitro Corporation, Silver Spring,-Maryland, supplied both safety-related
and commercial grade items; however, the supplier evaluation package did
not document evidence that the quality program for commercial grade items
had been evaluated as required in Section 7.1.3.10(b) of CR3's Nuclear
Procurement & Storage Manual (NPSM).
Hub, Incorporated, Tucker, Georgia, supplied safety-related items; however,
the supplier evaluation package did r.ot cocument that the vendor's qualifi-
catico audits / evaluations of subsuppliers had beer. evaluateo by CP3 as
required in Section 7.1.3.9(c) of the MPSM.
American Export Trcding supplied ASME Coce "N" stamped valves manufactured
by Anchor-Welirg, Williamsport, Pennsylvania, anc by Hirata Valve Industry
Company, Ka kaski, Japan. However,16either Anchor-Darling nor Hirata Velve
have been qualified by CH3 as approveo suppliers and placed on the ANSL.
]
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Bubcock & Wilcox, Lynchburg, Virginia, was audited by CR3; however, the
scope of the audit and qualification did not include field repairs of
in-core cetectors performed under Work Authorization ho. H1893D00. 1
Ocl2ar Installation, Services Corrpany, Lekeler6, Florida, supplied safety-
related items to CR3; however, the supolier evaluation package did rot i
document that the quality program manual had been revkwed as required in
Section 7.1.3.3 of the CR3 NPSM. l
l
Colt Industries, Fairoanks Morse Engirie Divisicn, Beloit, Wisconsin,
supplied safety-related items; bcwever, the supplier evaluation package
did not document that CR3 had performed an implertientatiori audit.
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2.3 Review of the CR3 Commercial Grade Supplier Evaluations
Under the licensee's program, commercial grade suppliers (catalog type items) are 4
approved and the evaluations are documented by a vendor quality evaluation report l
(VQER) based on the satisfactory evaluation of a minimum of one of the following: l
(1) survey results indicated in the latest edition of the CASE register, (2) quality !
manual review documented on the YQER (MIL-Q-9858, MIL-I-45208, and ASME Section l
VIII, are considered by the licensee to be consistent with 10 CFR Part 50, '
Appendix B), and (3) product performance review data from sources such as hPRDS
or INP0 SEE-IN data systems, NRC Bulletins and Information Notices, NUREG-0040,
or applicable Military Specification Qualified Products Lists. Suppliers of
calibration services are evaluated on the basis of the suppliers' response to
a calibration service questionnaire and may include a quality program manual
review and/or a review of other nuclear evaluations.
A review of seven commercial grade supplier evaluation packages revealed that ,
all seven suppliers were placed on the ANSL and subsequent procurement made i
without a facility audit of the supplier by CR3 to verify implementation of the
supplier's quality program or to verify the basis of accepting certificates of )
conformance. A description of several of these suppliers and associated issues I
are given below.
J
Borg-Warner was chosen to supply a compressor purge unit for the chilled
water system on the basis of an evaluation of an ASME Section VIII quality
program. However, this is not an adequate basis for approval, since
Section VIII does not cover nonmetallic materials, electrical items, or
other nonpressure retaining components of the purge unit compressor.
Additionally the compressor assembly would not contain an ASME Section
VIII pressure vessel component.
"
Bolt Irdustries, Ocala, Florida, was chosen to supply anchor sleeves
without a facility implementation audit to establish the bases for CR3 l
to accept a certificate of conformance. '
'
Worthington Pump Coiiipany, Harrison, New Jer ny, was chosen to supply a {
pump impeller (P0 No. F16936K) in August 1983. Worthington was qualifiec
as on approved supplier based on a CASE audit that contained a conditional l
J
approval status from 1977 to April 1985 enly for the Hi.rrison, New Jersey 1
facility. However, the supplier evaluation package did not document the
control of procurement octivities regarcing certain manufacturing facilities
or other restrictions noted in the CASE aucit. ,
i
Woodward Governor Company, Fort Collins, Colcrado, was approved as a i
supplier on the basis of a CASE audit that contained the following l
quality program restrictions: (1) quality assurance (QA) does not perform
design reviews; (2) outgoing purchase orders are not reviewed by QA; (3)
QA does not ma1ntain en approved list of suppliers end does not control j
placement of purchase orders; and (4) the Woodward audit program does not I
include vendors or address seismic and equipment qualification requirements. )
The licensee's supplier evaluation package did not document the control of l
procurement activities regarding the restricticos identified in the CASE
audit.
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Automatic Switch Company (ASCO) was qualified on the basis of an audit
performed by Florida Power and Light (FPL). FPL had placed a restriction
on ASCO requiring that source surveillance be performed during final
airtest and that operational tests be performed on completed valves. The
CR3 supplier evaluation package did not document control of procurement
activities regarding the restrictions noted in the FPL audit. Seven ASCO
purchase orders were reviewed and none contained requirements for source
inspection.
2.4 Review of the CR3 Approved Nuclear Suppliers List (ANSL)
The results of the CR3 supplier quality program evaluations are documented
and the status maintained on the ANSL. Although the ANSL identifies suppliers
best qualified to furnish safety-related items or services, purchases may be
made under the commodity or verification methods. (refer to Appendix B of this i'
report) with companies that are not listed on the ANSL. Consnercial grade
commodity vendors supplying generic type items or services are not required to
be on the ANSL, unless noted on the commodity evaluation sheet. A commercial
grade vendor must be on the ANSL when purchases are for (1) nonstandard mill
,
lengths or broken lots, (2) items that are not marked by the manufacturer and ]
!
critical characteristics are specified that require mandatory verification upon ]
receipt, or (3) fasteners. The inspectors reviewed the connodity evaluation '
sheets for P0 No. F9034051C (Consolidated Electric), PO No. F9024651C (House of
Treads), and P0 No. F16461C (H. A. Busbee), which indicated that the supplier
was required to be on the ANSL; however, the documentation showed they were
not.
Nuclear supplier evaluations are valid for a period of 3 years from the date
that the last facility audit was performed (may be performed by other than CR3)
and evaluated. Commercial supplier evaluations are valid for a maximum period 1
of 3 years from the actual onsite CASE " survey date" as listed in the latest d
revision of the CASE register cr the actual cate of the performance and/or the
QA Manual review. Suppliers initially approved for a period of more than 1
year will receive an arrual performance review. All approvals and reapprovals
are incorporated into the ANSL. The ANSL itself is not used as a decisico
rwing instrument, but rether as o listing" only. The procurement and i
materials quality assurar.ce group revicws the vendor evaluation package icr
each purchase order and selects the approvea supplier cr the basis of the
documented evaluation in each package.
3. LICENSE / VEND 0R INTERFACE
3.1 Processing of Incoming Yendor-Related Information
The NRC inspectors reviewed the processing, evaluation, and actions taken l
for: Babcock & Wilcox (B&W) Transient Assessment Program (TAP) Reports, MW '
Potential Safety Concerns (PSC), B&W 1ettert, Byron Jackson Service Notes
and Bulletins, Colt Emernency Diesel Service Information Letters, NRC
communications, and other vendor information including 10 CFR Part 21 notifi-
cations. The licensee / vendor interface process at CR3 is primarily described ;
l
in CR3's Nuclear Operating, Licensing, and Administrative Frocedures. The CR3 1
procedures for controlling this process are:
N00-C6, Technical Information Program
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- NL-03, Nuclear Licensing Procedure, Correspondence
- NL-06, Nuclear Licensing Procedure, Resolution of Safety Concerns
AI-404, Review of Technical Information
- DC/RM 375, Routing and Processing Incoming Technical Information
Additional procedures are used by the licensee for specific actions
associated with the process. During the inspection, the inspectors reviewed
the licensee's training on these procedures and the control of technical
information. Recently revised Procedures, N00-06 and AI-404, identify
areas of responsibility and describe the review and processing of most
technical information received by the licensee. Procedure AI-404 outlines
the tracking of the initial evaluation as well as the associated corrective
actions.
Nuclear operations personnel familiar with the process are required to
affix a vendor and technical information routing slip to the material
received and identify applicable review requirements on the slip. During
the inspectors' review of this process, it was found that several engineers
interviewed were either not aware of these procedural requirements or
disregarded the guidance. The primary deficiency associated with the
review of AI-404 was that virtually anyone onsite could be a recipient of
vendor furnished technical information to CR3. As a result, technical
information may be erroneously classified as "no evaluation required,"
sent to docuinent control, and filed without the benefit of an evaluation
for applicability to CR3. The review indicated that vendor technical
information was not properly processec, evaluated, and dispositioned. The
inspectors were additionally concerned with this Aficiency to follow
procedures because several individuals interviewed were trained in the
handling of incoming technical information previously 'and should have been
familiar with the process. During the inspection the licensee wrote j
Nonconforming Operating Report 89-84 identifying similar problems resulting
from a lack of training that have the potential to affect the operability {
of plant components and systems. Hcwever, this action appeared to have
been prompted by the NRC's visit to CR3 Leveral wee k before the inspection
and, as such, credit fcr self-identification by the licensee has 140t been
given.
1
CR3 procedures NL-06 arc NL-03 define the processing and responsibilities I
for the control of certain correspondence within the licensing department. j
Specifically, this involves the review and resolution of B&W potential safety i
concerns (PSCs), and other related safety concerns, including internally
generated issues, issues received from sources outside CR3, and compliance with
10 CFR Part 21 and 10 CFR 50.59 requirements. During the inspection, CR3
management proposed to process future reviews, evaluations, and resulting i
actions through a single group to ensure consistent and timely response to all
future technical communications received at CR3 frem suppliers.
3.2 Specific Vendor issues
During the inspectior,, various vendor communications were requested and
reviewed to verify proper receipt, evaluation, and disposition. The inspectors
identified areas where issues were improperly evaluated and others where
programmatic and specific deficiencies existed as well as concerns with the
timely disposition of vendor technical isstes. However, the B&W transient
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' assessment' reports (TAPS). appeared to be properly evaluated for applicability
- to CR3 and, with a few notable exceptions, NRC-information notices received an
acceptable level of. review. . Examples of deficiencies in the disposition of
oincoming vendor furnished technical'information are provided below.
.(1) B&W Potential Safety Concerns (PSC)
'
L .PSC 1-84 was issued to CR3 ;in December 1986 and dealt with a flow-
i~
induced vibration problem that could damage steam generator tubes
during'certain transients. The problem was originally identified
in 1984 by B&W;;however, owners were not alerted at that time to
the potential issue for reporting or corrective action. This.PSC
' has been opened at .CR3 for over 2' years with no projected date
l' established for completion.
PSC 3-87 was issued on October 20, 1987, to alert owners of a potential
r problem with the repair limit for tube plugging as identified in plant
Technical Specifications. The licensee closed the issue on the basis of
its preliminary findings with a final evaluation scheduled for the'first
quarter of 1988, which was when the licensee expected B&W to complete its
final evaluation.- As of the date of the inspection .the licensee's.
evaluation is still incomplete and the scheduled due date has now been '
established as' late 1989.
PSC 9-86 was issued on March 31, 1987, to alert owners of a' potential' -
problem with Bailey-supplied potentiometers that were found to have loose
internal parts.- The licensee investigated the problem and found that some
of the installed assemblies had free-play but were within an acceptable
tolerance. The issue was closed with the commitment to add cautions to
Procedures SP-112, and-113 to check for free-play during surveillance and
to replace assemblies as required. This disposition was performed in
January 1988; however, the cautions have still not been added to the
procedures.
'
FSC 15-86 was issued en February 16, 1987, to alert owners cf a potentihl
safety concern with pressurizer surge line thermal fatigue. The licensee
closed the issue a yedr latet as d result of the issuance of NRC
Information Notice 88-80 which notified licensees cf a similar problem
that occurred at Trojan. The tinal resolution will t,e handled in
c.ccordance with CR3's response to NRC Eu11etin.88-i.1. This is another
example of an untimely response to a generic safety concern.
(2) Vendor Information Received At CR3
Terry Turbine issued a letter on July E3,1985, to alert owners of
pcssible prob 1ss relating to the seismic requirements for turbine-to-
pedestal botting. The licensee evaluated the issue on April 6, 1988,
and recommended inspecting the bolts during the next disassembly of the
,
turbine. The inspectors determined this evaluation to be inadequate
because it may be years before the inspection is performed, if at all.
Additionally, several of the bolts and studs car, be visually inspected
without disassently of the turbine to determine their identification ana
seismic qualification.
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General Electric Service Information Letter No. 44 was issued on
June 25,.1987, to inform licensees of the need to perform HFA relay
pickup voltage adjustments. Initially the licensee stated that the
relays would be tested; however, the CR3 maintenance department did
,
not agree with the original evaluation and subsequently determined
that the testing was not required. This evaluation is inadequate
since the HFA relay pickup voltage adjustment is necessary to ensure
proper operation.
Limitorque Corporation issued a letter on August 13, 1985, to alert
licensees to a potential failure mechanism within the worm gear shaft
for certain valves used at CR3. The licensee determined that the valves
were not operated in the manner. described in the letter so the issue was
closed. This evaluation was inadequate because if the valves are operated
-or tested in this manner in the future the failure may occur. A caution
should be added to the CR3 procedures or equipment manual to preclude the
potential for this type of valve failure.
Seven of 12 Byron Jackson Service Notes and Techr'aal Alert Bulletins
issued to CR3 were noted as being completely evt dated as required by
the CR3 program. .The balance of the technical bulletins issued were
not fully reviewed, documented, or input into the system. .
Terry Turbine has issued several_ design improvements and other corre- -
spondence identifying problems and modifications applicable to its ;
turbines. CR3 was only aware of letter Number 14, which was received by
CR3 during a Terry representative's visit to CR3. The notification had
never been entered into the technical information program. An improved
vendor interface program should be established with Terry Turbine and
other " key" manufacturers of safety-related equipment.
Fisher Controls has issued six Fisher Anomaly Notices since 1986; however,
only one notice was received by CR3 through a Fisher representative. It
i s currently unclear what effect the other notices may have on CR3. This
is ancther example cf the importance of rauir,taining formal contact with
key vendors of safety-related equiprLent.
(3) Review of CR3's Evaluation of HRC Inform tion Notices (Ihs) !
IN 87-66, " Inappropriate Application of Comercial Grade Components,"
was issued to alert licensees to potential problems resulting from
inappropriate application of commercial grade components within
qualified Class IE electrical systems and to identify the differences ;
in the quality and qualified life expectancy between manufacturers'
nuclear and commercial grade relays and other componentt. The
licensee determined that no action was required because the purchase, i
storage, and issuance of parts and materials for CR3 is controlled by i
CR3's Nuclear Procurement and Sterage Manual. During discussions I
with licensee personnel, it was revealed that the above disposition
was concluded without any specific program review and without the )
benefit of assigning any review tasks to the cognizant groups. It was
also noted that the licensee's evaluation did not address the aspect
of qualified or projected life expectancies of the Agastat relays, 1
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which are two years from the date of manufacture for consnercial grade
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7000; series;,while its safety-related counterpart, the E7000 series, 4
has a 10-year. or'25,000 cycle life expectancy. An example of a consnercial
grade Agastat . relay upgraded by CR3 and installed in a safety-related
l application is> described in Section 1.2 of this report.
,
IN 88-35, " Inadequate Licensee Performed Vendor: Audits," was issued to .
alert licensees to potential problems relating to recent instances of 1
licensees performing inadequate audits at vendor. facilities. The IN
describes specific examples.in which the NRC identified numerous and/or
H
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significant problems with vendor audits despite previous licensee audits
~that should have identified such deficiencies. The licensee indicated that
it had revised Procedure QAP 30, " Vendor Audits," to add a requirement for i
I
the QA/ procurement department to review the proposed vendor and product l
that will be audited to determine the extent of technical suppart required
'
to support the audit. This action.is inadequate since it did not address
7 the concerns discussed.in the IN that licensees may not be adequately
implementing their QA program requirements, especially Criterion VII
'of 10 CFR Part 50,' Appendix B. For example, the'Amerace Corporation,
manufacturer of Agastat 7000- series timing relays,. was referenced in j
the IN as:a supplier who failed to adequately establish and implement a QA I
program in several areas, as identified during an NRC inspection performed
in 1986. However, CR3's evaluation of the IN did not recognize this fact,
,
but only noted that additional auditors may be.necessary to support future
audits.. Licensees also were reminded of their responsibility to assess;
the effectiveness of their contractors' quality control program by such
actions as verifying the validity of and the basis for manufacturer / vendor
records, such as certificates of conformance.
IN 88-56, " Potential Problems With Silicone foam Fire Barrier Penetra-
tion Seals," was issued to alert licensees.to potential problems with
silicone foam (SF) sealant material used in fire barrier penetration
seals. Problems with SF sealant material may result in the reduction
of- the fire-resistive capability for protecting safety-relateo redundant
equipnent, including electrical power and control circuits. The
licensee's evaluation of the IN states that CR3's Station Procecure (SP)
407 is used on an IS-sponth frequency to inspect such problems. The
inspection attributes of SP-407 requires that CP3 personnel verify that
there.are sio cracks greater than 1/8-inch in width in the sealant
Udterial, no holes greater than 1-inch deep, no tears or rips, a M cables
are not pulled away from sealant material.
Subsequent discussions with CR3 fire protection perso.nnel determined
that contrary to SP-407, a visual observation of the SF sealant material
in the fire barriers cannot, in most cases, be performed oecause the
material is covered by 1-inch thick fire-resistant boards on beh sides uf
wall. penetrations and on the bottom of flocr penetrations. The NRC
inspector asked whether or not during CR3's previous 1987 and 1988
inspection activities -(performed using SP-407), the fire boards had been
removed to inspect the attributes delineated in the procedure. CR3
personnel stated that they had not and that the inspection was limited to
, only the surface of the fire-resistant board. The NRC inspectors reviewed
I
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the previous two inspection reports (May 1987 and July 1988) performed in
accordance with SP-407 and noted the following:
-
Approximately 1,700 safety-related penetrations are listed.
-
The May 1987'and July 1988 inspections consisted of 445 and 112
staffing hours,.respectively.
-
.The CR3 senior fire protection engineer stated that the inspections
were performed by CR3 consultants.
-
The inspector who performed the 1988 inspection performed over 500
penetration seal verifications during a 1-day period.
-
The validity of the inspections is questionable because strict com-
pliance to SP-407 is not possible for penetrations where the SF.
sealant is covered by the 1-inch thick fire-resistant boards.
The inspector. concluded that the licensee's evaluation and dispostion of
the IN was inadequate since SP-407, as written, cannot be implemented
effectively because of the fire board material obstructing the inspection.
IN 86-07, " Lack of Detailed Instruction and Inadequate Observance
of Precautions During Maintenance and Testing of Diesel Generator
Woodward Governors." CR3 incorporated this guidance in procedures
MP-117 and SP-605, " Emergency Diesel Generator's Governor and Servo-
Booster Maintenance," however, SP-605 did not address filling and
venting the EDG governor and adequate observance of precautions
during maintenance and testing as addressed in the IN.
3.3 Timeliness of Vendor Evaluation Performed by CR3
Timely reviews, evaluations, anc corrective actions for incoming technical
information was thd subject of a recent NRC-identified violction at CR3.
During the inspection, the NRC inspectors ah noted several similar exan:ples.
Several TAP reports (e.g., AN0-88-02, -03, -C4, and TMI-88-01) and selected NRC
information notices (e.g., IN 88-80) had rot been reviewed for applicability to
CR3. These communications were several months to o year old. Timely reviews
for applicability are important to avoio events er equipnent fanures similar
to those experienced at other plants.
3.4 Em_ goy:cy Diesel Generator Interface
The CR3 errwgency 4 diesel generators (EDGs), Model 38TD8-1/8, were manufactured
by Colt /Fairbanks Morse Ergine Division (FMED) and delivered before the 1977
initial startup of CR3. Rated at 2750 Kilowatts at 0.8 power factor continuous,
EDG 1A has 1784 operating hours and EDG IB has 1408 operatir;g hours. The
engines'are opposed piston, turbocharger, and generator shaft driven. The
licensee has communicated directly with Colt Industries, Beloit Wisconsin, with
regard to. service information, assistance, and spare / replacement parts since
the original installation.
The licensee's philosophy for performing maintenance activities on the EDG
engines is to accomplish relotively minor and routine tasks using CR3
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maintenance personnel and complex tasks using assistance from Colt Industries. H
The Florida Power Corporation (FPC) Training Center trains operations and d
maintenance personnel on the EDGs at least once every 2 years. The instructors
and the diesel system engineer are the only personnel who have attended Colt's
2-week diesel course held in Wisconsin. The CR3 operators attended courses ROT
4-6, " Emergency Diesel Generator;" AN0-105, " Emergency Diesel Generator Engine,"
and ANO-106, " Emergency Diesel Generator Electrical" which are conducted at the
FPC Training Center. The maintenance personnel attended Lessons 07-42,
" Emergency Maintenance / Emergency Diesel Generator," and 05-46, " Mechanical
Maintenance Emergency Diesel Generator." The trainir.g curriculum also includes
t- the use of event and deficiency reports such as licensee event reports, NRC
information notices, 10 CFR Part 21 repurts, and Institute for Nuclear Power
Operations event' reports to keep personnel informed of EDG engine problems.
3.4.1 Review of Colt /FMED Manuals and Other Technical Information
l
Colt /FMED Service Information Letters (SILs) are filed in Volume II of the
technical manuals; however, appropriate pen and ink revisions to the manuals
indicating SILs that may be applicable to the EDGs were not made. Colt Repair
and Service Information Letters (R&SILs) dating from 1974 to 1980, pertaining
to Model 38TD8-1/8, were not sent by Colt to the licensee. As a result, the I
licensee contacted Colt /FMED during the first week of the inspection to request !
a set of the R&SIls that it will evaluate for applicability. Some of the 5 l
R&SILs, covering such topics as flexible couplings, exhaust manifold screens, )
and fuel header hose replacements, have been implemented by the licensee under l
the direction of a Colt technical representative. Colt /FMED operating and !
maintenance manuals at CR3 are controlled copies. )
i
3.4.2 Review of Colt /FMED SILs j
l
The inspectors reviewed the SILs issued by Colt /FMED that were applicable l
to the EDGs to determine whether they had been properly considered and l
1mplemented. The applicable documents consisted of 14 51Ls (A-1 through A-17 I
with the exception of A-6, A-9, and A-10, which did not pertain to CR3). The
licensee's procecure involves the use of CR3 Prccedure AI-404, " Review of ,
Technical Information," to evaluate vendor-stelied techt ical information. The i
most significant deficiency identified during the inspection involved six Sils l
that were not entered into the 14censee's sy stem until April 6,1989, almost 2 l
years ofter receipt at CR3-. As a result of this example, the NRC inspectors I
reviewed training records of CR3 employees whc were trair.ed in the W4Ca i
procedure. This review identifiM 6 approximately 50 employees, incluaing the
EDG system engineer, who recewed training on the Al-404 procedure. An
inherent weakr.ess in the procedure is the fact that incoming technical
information to CR3 can be receiven virtuclly by anyone nnsite (approximately
500 employees), thereby increasing the likelihood that information could be
lost or improperly categorized. As a result, the Document Contrcl Department
may never receive such information. During the inspection the licensee stated
that form 1 contractual arrangements have recently been made with its " key"
safety-related suppliers. The licensec identified one individual as the point
of contact to address all technical informtion to help avoid future problems
in this area. '
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The inspectors reviewed the licensee's evaluation, implementation, and-
corrective actions for the 14 Colt /FMED SILs pertinent to the CR3 EDGs and
the results are as follows:
A-1, Scavenging Air Blower Rotor Clearances When Using The Turbo Blower
Parallel-Scavenging Air System
Evaluation - Proper blower operation is essential to reliability of the
EDG.
Action - A change to procedure SP-605, " Emergency Diesel Generator
Engine Inspection / Maintenance" was performed. The inspectors' review of ,
SP-605 revealed a provision to inspect the blower and measure rotor
clearances. However, no acceptance criteria had been established by ;
' the licensee to verify acceptability eventhough the SIL provided 1
acceptance criteria.
.A-2,' Blower Installation'
Evaluation - Proper blower operation is critical to performance of the EDG.
Action - Add notes to procedure SP-605. A review of SP-605 revealed no ;
reference to SIL A-2 or precautions to take after installation of the
blower and before engine startup.
A-3,InletAirCheckValveLubrication(turbochargerairinletduct)
Evaluation - Proper. operation of the inlet air check valve is ,
essential-for operability of the EDG.
Action - Add to Preventative Maintenance (PM) program. Lubrication -
of the inlet air check valve was implemented by the licensee for
both EDGs.
A-4, Generator Bearing Insulation
Evaluation - EDG reliability may be impaired with possible degradation of
the generator bearing insulation.
Action - Add this information to the PM program. It was observed that
the licensee did not implement the action recorraendec.
A-4, Rev. 2, (1ssued February 20,1989)
Evaluation - Failure to check bearing insulatior. cculd lead tc a f allure
to detect insulation breakdown, which may result in a crankshaf t bearing
.
failure.
f Action - Incorporate into PM-123 scheduled for completion by March 22, 1589. !
TeIEri nded action was not ac c mplished as of the date of the inspection. l
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'A5 Engine Run-In Procre,iure
Evaluation - Proper engine break-in (new or after repair) is essential to
increase reliability of the EDGs.
Action - Add to the Colt technical manual and procedure SP-605. A review
by tfie inspectors identified that SIL A-6 had not been referenced in the
procedure.
A-5, Rev. 1, (1ssuedJune 22,1987) This SIL was placed into the system
during the inspection in accordance with AI-404 " Review of Technical
Informatic." on April 25, 1989. No evaluation had been performed as of
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L the date of the inspection. Credit for self-identification has not
l been given to the licensee since this issue appears to have been
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prompted by the NRC inspectors' visit.
A-7, Air Inlet Housing
Evaluation - A loose baffle plate could impair air flow which would
decrease engine reliability.
Action - The licensee stated that the baffle bolts were checked on a
sTx month interval by the EDG system engineer, however, documentation
was not available to support this inspection. The licensee stated
that the item will be incorporated in a CR3 procedure in accordance
with NE-86-0054, scheduled to be completed by May 30, 1989. As of
the inspection, this-action had not been accomplished.
A-8, Rotor Housing Clearances
Evaluation - Proper blower operation is essential to EDG reliability.
Action - The SIL was filed in Voluna II of the Colt Technical Manual.
Procedure SP-605 contains a requirement to inspect blower rotor-to-
housing measurements but contains no acceptance criteria to properly
evaluate the measurements nor does it refer the technician to the SIL,
which does contain acceptance criteria.
A-11 to A-16, (Issue date June 22,1987) During the inspection, it was
identified that these SILs were in the possession of the EDG system
engineer and were not entered in the licensee's technical information >
system per procedure Al-404 until April 6, 1989. As a result, no
evaluation had been performed while in the possession of the system
engineer. The licensee is presently evaluating the significance and
applicability of these SILs.
A-11, Timing Chain Inspection
A-12, Marking of Lubricating Cil Level Bayonet Gages
A-13, Piston Ring Combination i'
A-14, Water Treatment for Er.gine Cooling System
A-15, Annealing Copper Gaskets
A-16, Eentval of Anti-Freeze from Engine Lubricating til
System
A-17, Fuel System (Issued April 22,1969) Th n Slt was placco into the j
licensee's system on April 25, 12 9. No eve Mtion had been performed
as of tMs insper. tion.
!
At. a result of their review cf Colt technical informatica, the inspectors !
concluded that the licensee had not performed complete and timely evaluations j
of information provided by Colt /FMED. In addition, the licensee's system for
receipt, tracking, evaluating, and disposition of EDG technical information was
deficient and should be reviend and improvec to ensure that all such information
is properly received, evaluated, dispositioned, and referenced, as applicable, l
in the appropriate diesel manuals. At the conclusio9 of the irispection, the '
licensee stated that a formal program has recently been estabiisned with l
Colt /FMED to ensure that all technical it. form. tion pertinent tc CR3 EDGs is
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received and processed through a central individual. A similar arrangement
.has also been established with Babcock & Wilcox, the nuclear steam system
supplier, and Brown Boveri, the supplier of electrical switchgear. This action
taken by the licensee is primarily in response to the reconnendations given in
3.4.3 Review of CR3 EDG Procedures i
.l
The inspectors reviewed the following procedures and found that they were I
inadequate with respect to their ability to provide appropriate acceptance
criteria for determining that important activities have been satisfactorily
accomplished. These inadequacies are examples that contributed to PEF
89-200-03. -
Results of testing conducted on December 9,1987, under SP-354B, " Monthly
Functional Test of the Emergency Diesel Generator EDG-1B," Revision 18,
documented variations in individual cylinder exhaust temperatures of
280*F, while the differer.tial cylinder exhaust temperature is limited to
250*F by the vendor's technical manual. A review of testing performed on
June 28, 1988, conducted to Revision 21 of the procedure also contained
a variation greater than 250'.
SP-605, " Emergency Diesel Generator Engine Inspection / Maintenance,"
Revision 16, dated March 6,1986, lacked quantitative acceptance
criteria for performing an effective inspection of the EDG blower
assembly. Revision 20, dated September 23 1987 also lacked acceptance
criteria for blower-to-casing clearance mea,sureme,nts. The blower assembly
was inspected by the licensee on September 29, 1987, and determined to be
satisfactory despite a lack of documentation certifying the basis for
acceptance. Although acceptance criteria were provideo by SILs A-1 and
A-8, the procedure had not been revised to incorporate the criteria or
reference the SILs.
l
3.4.4 EDG Housekeeping l
In gereral, housekeeping of EDGs IA and IB was poor. The irspectors inspected
the EDGs on April 25 and 29, 3939, and four.d oil dripping from the ejectors are
related piping. According to CR3 Frocedurt EP-300, " Operating Daily Surveil k nce
Loy," es. cess oil should be wiped up three times caily. The it.spectors informed j
the licensee of this finding during the inspection and corrective action was i
cormitted to by CR3 management. I
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APPENDIX A
PERSONS CONTACTED
Florida Power Corporation
W. W11gus, Vice President, Nuclear Operations
G. Boldt, Vice President, Nuclear Production
E. Renfro, Director, Nuclear Operations Material and Control
R. Widell, Director, Nucicar Operations Site Support
G. Westafer, Director, Engineering Quality Assurance
E. Simpson, Director, Engineering and Projects
P. McKee, Director, Nuclear Plant Operations
W. Rossfeld, Manager, Nuclear Compliance
K. Wilson, Manager, Nuclear Licensing
C. Tillman, Manager, Material Control
R. Watts, Manager, Purchasing and Contracting
G. Becker, Manager, Site Nuclear Engineering Services
K. Baker, Manager, Nuclear Engineering Assurance
H. Harmon, Manager, Nuclear Records Management
D. Kurtz, Manager, Quality Audits
S. Johnson, Manager, Site Nuclear Services
P. Tanguay, Manager, Nuclear Operations Engineering
C. Ingram, Manager, Nuclear Projects
K. Lancaster, Manager, Site Nuclear Quality Assurance
L. Tiscione, Manager, Nuclear Procurement Engineering Services
G. Oberndorfer, Manager, Procurement and Material Quality Assurance
E. Froats, Nuclear Licensing Supervisor
L. Moffatt, Nuclear Safety Supervisor
L. Floyd, Nuclear Docun.ent Control Supervisor
P. Breedlove, Nuclear Records Management Supervisor
M. Williams, Nuclear Reguietory Specialist
J. Cooper, Nuclear Technical Support Superintendent
J. Tunstill, Senior Nuclear Licensing Engineer
D. Nusbickel, Ser.ior Nuclear Electrical Procurement Engineer
S. Ulm, Nuclear Engineering Assurance
E. Good, Senior Nuclear Licensing Engineer
Nuclear Reculatory Commission
- E. William Brach, Chief, Vendor Inspection Cranch (VIB), Office of
Nuclear Reactor Regulation
- E. Baker, Chief, Reactive Inspection Section No.1, VIB
- F. Jape, Chief, Quality Programs Section, Region 11
- R. Crlenjak, Chief, Reactor Projects Section 2B, Region II
- P. Holmes-Ray, Senior Resident Inspector, CR3
- J. Tedrow, Resident Inspector, CR3
- Attended exit meeting
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l. APPENDIX B
PROCUREMENT PROCESS AND PROCEDURES
The procurement of material, equipment, services, storage, and issue of all
items used at CR3, except nuclear fuel, is governed by. procedures contained
in the Nuclear Procurement and Storage Manual. The manual defines respon-
sibilities of individual departments and provides interfacing of regulatory and
Florida Power Corporation (FPC) requirements relating to procurement, storage
and material issue activities.
It should be noted that materials, equipment, and services; including replacement
components and " piece-parts" classified by CR3 as safety-related, are. subject
to the requirements of 10 CFR Part 50, Appendix B, " Quality Assurance Criteria
for Nuclear Power Plants and Fuel Reprocessing Plants," and 10 CFR Part 21,
" Reporting of Defects and Noncompliance." It should also be noted that these
requirements apply to facilities licensed under 10 CFR Part 50, regardless of
the original basis or quality assurance (QA) standard under which the facility
was constructed.
A facility licensed by the NRC under 10 CFR Part 50 may choose to procure
parts, equipment, or services for use in safety-related applications from
suppliers who do not maintain a 10 CFR Part 50, Appendix B, QA program,
provided the facility institutes its own measures to ensure that the procured
materials are of adequate quality and suitability for normal operating,
seismic, and harsh environmental conditions. In the course of inspecting the
CR3 procurement program and its implementation, the NRC inspection team
reviewed the following sections of the CR3 Nuclear Procurement and Storage
Manual.
Section Title
1.0 Administration of the Nuclear Procurerrent and Storage flowal
2.0 C'assifitaticn of Items and Services for CR3
3.0 Gereral Requirements for Procurement Pocuments
4.0 Purchases of NonSafety-Related (NSR) Iterrs and Services
5.0 General Purchase Pecuirements cf Safety-Felated (SR) Items
and Services
6.0 Saf ety-Related Procuremen: Methods
7.0 Evaluation and Control of Supplier Qua',!ty Performance
8.0 Receipt of Shipments and Receiving Inspection
9.0 Disposition of Nonconforming Items
10.0 Notification and Investigation of Nonconfonnances Discovered
After Acceptance of Items for Use
11.0 Handling of Material (SR and NSR)
13.0 General Requirements for Storage of Items
16.0 Obtaining Items from Stores
As previously stated, the overall procurement process at CR3 is governed by the
Nuclear Procurement and Storage Manual. Administrative controls of the manuel
are contained in Section 1.0, " Administration of the Nuclear Procurcraent and
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Storage Manual" which describes the responsibilities of various organizations
in implementing the manual.
FPC management designated responsibility for the development, issuance, control,
and revision of the manual to the Nuclear Procurement and Storage Committee.-
The comittee consists of representatives from various departments: Nuclear
Engineering, Quality Programs, Nuclear Operation Materials Purchasing and
Contracting, Nuclear Operation Material Control, and Nuclear Plant Maintenance.
The connittee monitors the effectiveness and adequacy of the manual. All
revisions to the manual require the committee's approval.
All items or services procured for application in CR3 are classified as " safety-
related (SR)" or "nonsafety-related (NSR)" for CR3 according to Section 2.0,
" Classification of Items and Services." The fully integrated materials information
system (FIMIS)providesspecificengineeringclassificationsofSRandNSRfor
each material part number. Items for SR applications are procured using the
methods described in Section 6.0, " Safety-Related Procurement Methods." The
methods are: ,
"D" - specification method
"
"V" - verification method
"K" - catalog method
"C" - comodity method
The specification or "D" procurement method is used when specific controls are
required during the manufacture of SR items or services. The controls are
implemented to ensure that all technical and quality assurance requirements for
the item purchased or service performed are met. Because the items have
unique design or specification requirements, they cannot be procured on the
basis of a manufacturer's catalog or industry standards alone. This method
is the most restrictive method for the procurement of SR items or services and
is cr.e of the two methods FPC may use to infose 10 CFR Part 21 requirements on
the supplier of safety-related products or services procured. Specifications
for those items or services procured using the "D" n:ethod are prrxided by an
assigred nuclear engineering design engineer. Thost specifications include
technical requirements, applicabic codes and standards, drawings, procedures,
inspections. tests, ccceptance criteria dccumeatatice. and qualification
requirements (environmentalandseismic.$asapplicable. The supplier also
must to be on the approved nuclear suppliers list (ANSL).
The verification or "V" procurement method is the second nethod whereby 10 CFR
Part 21 requirements may be imposed on the supplier of the item or service
procured. This method is used to purchase SR items or services when the
,
supplier does not produce items under an Appendix B, QA program. Unlike the q
"D" method the vendor is not required to Le on the ANSL. Therefore, thorough j
identification of design requirements and verification by FPC is required to
ensure that critical characteristics are acceptable. The Nuclear Engineering
i
Department identifies pertinent requirements on a SR procurement requisition
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checklist form. The procurement checklist should identify all critical I
characteristics and the methods to verify such critical characteristics. 4
The Procurement Quality Assurance Department will review the requisition and
I prepare the requirements to be reviewed during receipt inspection (Section 8.0
I
of the manual) or during source inspection (Section 8.0 of the manual). This 1
method can be used to procure both safety-related and commercial grade items. )
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Comercial grade items are also purchased for application in SR systems under
the catalog or "K" procurement method. Items may be purchased under this
method when the manufacturer's published product description is adequate for
meeting the technical requirements of FPC. The item or service may be
purchased direct from the manufacturer or through a distributor. However, if
purchased from a distributor, the distributor must furnish the item in full
accordance with the catalog and the manufacturer of the item must be on the
ANSL. The Nuclear Engineering and Procurement Quality Assurance Departments
must identify critical characteristics and a method for verifying such
characteristics to ensure an adequate dedication.
The final method for purchasing SR items or services for application at CR3
is the comodity or "C" procurement method. This method allows for the
procurement of commercially available items or services and only is used when
the Nuclear Engineering Department has established that the item or service
will not prevent SR systems from performing intended design functions. Items
purchased using this method are generally produced in accordance with
nationally recognized codes and standards. As in the purchase of all SR items
or services at CR3, the Nuclear Engineering Department is responsible for
evaluating the item or service being procured for the safety applications it
must perform. In doing so the engineer must identify critical operating
requirements, applicable codes and standards, traceability, and documentation
requirements. The Nuclear Engineering and Procurement Quality Assurance e
Department shall develop an appropriate receipt inspection plan in accordance
with Section 8.4.3 of the manual. Proper establishment and verification of the
above requirements provides a method for dedicating the item for use in the SR
application for which it was intended.
To determine if a specific item or component is SR or NSR, it is necessary
to refer to the CR3 safety listing. When items or services are required, the
Nuclear Procurement Engineering Department must review all plant-initiated
procurement requisitions and FIMIS documents to verity that the correct safety
classification is applied. Section 2.3.3 of the manual describes the
conditicns under which services may be classitied as SR,
1
) Whf f! situations occur WhETC SR items dit. r.et available, FPC may upgrade NSR
items for use in SR systems. This upgrade is Irrformed according to Section
S.1 of the marual, " Disposition of NSR ltems for SR Use (or Storage): Material
Qualification." The department desiring to use the material or a design
engineer mdy request that allegedly icentical NSR items be evaluated as replace-
ments for SR items. Reviews are performed by several departments (Nuclear
Procurement Engineering, Procurement Ovolity Assurance, and Nuclear Materials)
to determine the adequacy of the item. The various departments must identify
key elements to establish suitability: method of traceability, characteristics
>
critical to safety, acceptance criteria for evaluating verification results,
special marking or instructions that should be attached, and any special test
equipment or instrumentation required for verification.
The NRC inspection team reviewed approximately 150 SR procurement packages to
establish the overall adequacy of the procurement process ciscussed in the
i preceding paragraphs. The Nuclear Procurement and Storage Manual contains many
key elements that, if implemented properly, are essential for ensuring the
proper procurement of items or services for SP application. A review of the
P-3
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procedures revealed several programmatic deficiencies. In addition, a review
of individual procurement identified numerous instances in which these prac-
l tices resulted in the installation of parts of unverified quality in SR
applications. Examples of these are discussed in Section 1.1 of this
l inspection report. The elements missing in the licensee's program that would
be necessary for adequate dedication would include, but are not limited to:
(1) establishing traceability of the component to its original manufacturer;
(2) definition of the safety function of the item to be dedicated and the
conditions under which it must perform; (3) identification of critical
characteristics or attributes, beyond a part number description, considered
vital to the item's ability to perform as required under all design conditions;
(4) review and technical evaluation of any changes in design, process, and
materials and of any effect on the suitability for nuclear applications under
all
sufficientdesign to conditions;
demonstrate (5) thatmethods for receipt are
critical characteristics inspection
met; andand testing (6)
,
detailed requirements for documentation of these actions.
- In implementing tN CR3 dedication program, the licensee failed in most cases
to establish traceability. Although many nonapproved or nonverified vendors
provided certificates of conformance (C0C), the licensee accepted them without
substantiating the validity or basis of the C0C, or verifying the vendors'
ability to make such certifications beyond a " desk" audit of the vendor. This
was particularly relevant in the cases of NSR items upgraded to SR via the
licensee's material qualification form process, for which traceability to the
original manufacturer cannot be assured since procurement records for items
originally purchased as NSR were not required to be maintained. In practice,
no engineering or technical evaluation, of form, fit, and function beyond
i verification of part number and nameplate data were documented. Therefore,
I
under this system, the process of dedicating or upgrading commercial grade
material for safety-related application at Cp3 lacks crucial elements. As a
result, the process fails to provide the assurance otherwise associated with
manufacturing under a 10 CFR Part 50, Appendix B, QA program that is audited
ena approved by the licensee, and the assurance, under 10 CFR Part 21, that any
c'eviations f rom technical procurettent specification would, as a minimum, be
reported to the licensee for evalu6 tion of the pntential for creating e
substantial saf ety hazard.
It shoulo be noted that the licensee has ccrur.itted to revise its procurement
progrem and procecures for cuamercial grade procurement, especially in the
areas c,f identification of critical characteristics ard vendor surveys beyond a
desk review of the vendor's QA manual. These revisions are expect 2d to be /
fully implemented by July 1969.
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