ML20247P675
| ML20247P675 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 07/28/1989 |
| From: | Whittier G Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GDW-89-247, MN-89-99, NUDOCS 8908040262 | |
| Download: ML20247P675 (5) | |
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MaineYankee RELIABLE f'LECTRICITY FOR MAINE $1NCE 1972 EDISON DRIVE. AUGUSTA, MAINE 04330.(207) 622-4868 July 28, 1989 MN-89-99 GDH-89-247 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:
Document Control Desk Washington, D. C.
20555
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) MYAPCo Letter to USNRC dated July 12, 1988 (MN-88-72)
(c) MYAPCo Letter to USNRC dated August 10, 1988 (MN-88-80)
(d) MYAPCo Letter to USNRC dated November 8, 1988 (MN-88-108)
(e) HYAPCo Letter to USNRC dated March 10, 1989 (MN-89-34)
(f) USNRC Letter to Maine Yankee dated June 7, 1989, NRC Inspection No. 50-309/88-200
Subject:
Response to Notice of Violation -
Inspection No. 50-309/88-200, Procurement Program Gentlemen:
This letter responds to ths Notice of Violations contained in Reference (b).
For completeness, we have restated the violations with our responses following. Our response is attached.
Should you have any questions on this matter, please contact us.
Very truly yours, MAINE YANKEE-
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l' G. D. Whittier, Manager l
Nuclear Engineering and Licensing GDH:BPB
Attachment:
Response to Notice of Violation l
c: -Mr. Richard H. Hessman i
Mr. Hilliam T. Russell Mr. Patrick M. Sears Mr. Cornelius F. Holden Mr. Hilliam V. Johnston 03791-RCC-00161 l
6908040262 890728 1g l
PDR ADOCK 05000309 Q
PDC i
j l
ATTACHMENT (Sheet 1 of 4)
10 CFR 50, Appendix B, Criterion XVII requires, in part, that sufficient
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records be maintained to furnish evidence of activities affecting 1
quality.
These records shall include the results of reviews, inspections, i
and material analysis. Criterion VII requires, in part, that measures be established to assure that purchased material and equipment conform to procurement documents.
The measures shall include provisions, as appropriate, for source evaluation and selection, and objective evidence of quality of purchased material. Criterion III requires, in part, that
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measures be established for the selection and review for suitability of application of materials, parts, and equipment that are used in safety related structures, systems, and components.
The Maine Yankee Operational Quality Assurance Program,Section II, commits to ANSI N45.2.13-1976, " Quality Assurance Requirements for the Control of Procurement of Items and Services for Nuclear Power Plantr."
ANSI N 45.2.13-1976, Section 10.2, states that., when certificates of compliance are to provide documentary evidence that items conform to procurement documents, means shall be established to verify the validity of supplier certificates and the effectiveness of the certification system, such as the performance of audits of the supplier or independent inspection or test of the purchased items.
Contrary to the above, as of July 22, 1988, Maine Yankee Atomic Power Plant installed numerous commercial grade items into safety related systems without adequately documenting their suitability for safety related applications in that records did not include the results of reviews, inspections, tests or material analysis nor was there source evaluation and selection or other objective evidence of quality of the purchased material which would validate the suitability of the material.
In addition, Maine Yankee Atomic Power Plant accepted certificates of compliance for purchased material.from vendors without verifying the validity of the supplier certificates or the effectiveness of certification system.
a.
The following are four examples of commerital grade purchase orders which lack adequate documentation of suitability for safety-related applications.
Twenty-six other examples are documented in NRC Inspection Report No. 50-309/88-200.
1.
PO 40755 - Replacement parts for four 125 volt vital bus invertors 2.
P0 42968 - Commericial grade BFD 44 and BFD 80 relays from Westinghouse Electric Supply Company (HESCo) installed in the main control board 3.
PO 44737 - Preferred Engineering for Reactor Vessel Stud Hole Plugs 4.
P0 43351-Gilman Electric for Westinghouse Circuit Breakers 03791-RCC-00161 l
MTACHMENT (Sheet 2 of 4)
L b.
The following are four examples of purchase orders whose material was accepted for safety-related applications based on certificates of compliance without verifying the validity of the supplier certificates or the effectiveness of the certification system. Six other examples are documented in NRC Inspection Report No.
50-309/88-200.
1.
PO 48520 - Nutherm for Westinghouse HCB 2400 Circuit Breakers 2.
PO 43032 - Solidstate Controls for Inverter 3.
PO 43582 - Versatile' Measuring for Alarm Indicator 4.
P0 44407 - Westinghouse Coils for 480 Volt Contractors MAINE YANKEE RESPONSE 1:
a.
Inadequate Documentation of Suitability for Safety Class Applications:
After a thorough review of this finding, we agree with the staff that Maine Yankee's documentation of the evaluation / dedication process to assure that commerical grade replacement components were suitable for safety class applications needed to be strengthened. Our documentation reviewed by the staff and noted above reflected that the evaluation / dedication process had been completed, and an equal to or better than finding had been made by a member of Maine Yankee's l
Engineering staff. However, the exact evaluation steps and actions taken were not sufficiently documented.
Following the staff's visit Maine Yankee committed to reviewing all purchases of the five years preceeding the audit to identify those that involved commercial grade components installed in safety-class applications, Reference (b). He developed guidelines and representative critical characteristics (using the EPRI-NP 5652 Procurement Guidelines) to be retroactively used for acceptance of the approximately 500 commercial grade purchases for safety class use. He then researched existing files and retrieved evidence showing that proper receipt inspection to the retroactively determined critical characteristics occurred.
In cases where existing records did not document full verification, an inspection of a sample of existing stock was used to complete the verification, j
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Maine Yankee is nearing completion of this review and a simultaneous effort to upgrade all documentation packages to be as close to current documentation practices as is practicable. Of the approximately 500 commercial grade purchase orders for safety class systems, 37 purchase orders remain to be completed.
To date, Maine Yankee has found one purchase order which was unacceptable.
This order pertains to instrument pressure tubing support clips. All of j
the clips furnished were located in stock (i.e. none had been used in j
the plant) and have been returned to the manufacturer for replacement.
03791-RCC-00161 1
ATTACHMENT (Sheet 3 of 4)
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1 Safety related molded case circuit breakers were also evaluated in response to NRC Bulletin 88-10. The status of this review has previously been provided tc the NRC.
Maine Yankee expects to complete its review of the remaining 37 l
purchase orders by September 1,1989 and will report on these orders by September 15, 1989.
To prevent recurrence of this item, Maine Yankee has revised its procurement procedures to improve the review, inspection, test and acceptance methods of commercial grade items intended for safety class systems, Reference (b).
In addition, Maine Yankee has recently developed a procedure for technical evaluations of replacement items which are not like-for-like.
This procedure provides improved guidance, consistency, and documentation for technical evaluations.
The procedure was developed using the EPRI Guideline for " Technical Evaluation of Replacement Items."
b.
Acceptance of Material without Validating Certificates of Conformance:
Maine Yankee agrees that procurement practices should inc?ude adequate documentation of acceptance. The application of the above procedures provides objective evidence of the reviews, inspections, tests or material analyses, and acceptance methods used which increase the level of assurance of the suitability of the item for its intended application. Our current. procedures require appropriate validation of certifications through vendor audit or other proper validation methods and documentation of the validation method.
Modification of our procurement practices, completed as described in part (a) of this response, should prevent recurrence of this item.
10 CFR 21, Paragraph 21.31 states that each NRC licensee shall assure that each procurement document for a facility, or a basic component issued by it on or after January 6,1978 specifies that the provisions of 10 CFR Part 21 apply.
Contrary to the above as of July 22, 1988, numerous procurement documents for procurement level 1 (safety related) material, which was purchased after January 6,1978, did not specify the applicability of 10 CFR 21.
The following are four examples of such procurement documents.
Thirteen additional examples are documented in NRC Inspection Report No.
50-309/88-200.
1.
PO 42784 - Quality assurance related safety class purchase of test equipment, troubleshooting and calibration services 2.
P0 45025 - Purchase of Safety Class IE Replacement Station Batteries 3.
P0 47714 - Satin American Co. for GE EC-1 Overcurrent Trip Devices for Breaker EZPB in MCC 8A and 8B 4.
PO 41352 - Henry Pratt for 24-inch Butterfly Valves in the Service Hater System 03791-RCC-00161
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