View source for GO2-83-862, Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-37.Corrective Actions:Procedure 13 Revised to Specify Use of Controlled Bill of Matls When Reviewing Purchase Requisitions

{{Adams
| number = ML20081J273
| issue date = 09/23/1983
| title = Responds to NRC Re Violations Noted in IE Insp Rept 50-397/83-37.Corrective Actions:Procedure 13 Revised to Specify Use of Controlled Bill of Matls When Reviewing Purchase Requisitions
| author name = Carlisle C
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
| addressee name = Martin J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION V)
| docket = 05000397
| license number = 
| contact person = 
| document report number = GO2-83-862, NUDOCS 8311080392
| title reference date = 08-26-1983
| package number = ML20081J259
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashington Way Richland, Washington 99352 (509)372-5000 Docket No. 50-397 September 23, 1983 G02-83-862 Mr. J. B. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

==Subject:==
NUCLEAR PROJECT NO. 2 NRC INSPECTION REPORT 83 NOTICE OF VIOLATION

==Reference:==
Letter D. M. Sternberg to C. S. Carlisle, dated August 26, 1983.
Washington Public Power Supply System hereby replies to the Notice of Violation contained in Appendix A of the referenced letter.
Our replies, pursuant to the provisions of Section 2.201 of the NRC's
    " Rules of Practice" Part 2 Title 10 Code of Federal Regulations, consist of this letter and the attachment which contains our response to the Notice of Violation.
If you have any questions or desire further information, please contact Roger Johnson at (509) 377-2501, extension 2712.
Program Director, WNP-2 RTJ/kd cc:   W.S. Chin, BPA N.D. Lewis, EFSEC A. Toth, NRC Resident Inspector Document Control Desk, NRC tg
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO. 2 DOCKET N0. 50-397 LICENSE N0. CPPR-93 NRC INSPECTION REPORT 83-37 NOTICE OF VIOLATION Statement of Violation As a result of the inspection conducted on July 18-22, 1983, and in accordance with the NRC Enforcement Policy, 10CFR Part 2, Appendix C, 47 FR9987 (March 9,1982), the following violation was identified:
Criterion XVI of 10CFR50, Appendix B states, in part, that " Measures shall be established to assure that conditions adverse to quality, such as fail-ures, malfunctions, deficiencies, deviations, defective material and equip-ment, and nonconformances are promptly identified and corrected."
Final Safety Analysis Report, paragraph 17.1.1.16 states, in part, that
          " Measures are established to provide for the prompt identification, eval-uation, and correction of conditions adverse to quality.... The Quality Assurance programs for the project organization...are required to estab-lish provisions: b. That corrective action for significant conditions adverse to quality identify the cause and include actions to preclude recurrence."
Contrary to the above requirements, actions were taken to gold plate die-sel generator air start transfer relay no. K17 contacts to prevent contact oxidation. However, similar actions were not taken for the spare relays nor was the diesel generator instruction / maintenance manual revised to indicate the requirement for gold contacts on relay no. K17. The failure to take these actions could result in reoccurrence of a sticking relay contacts condition and loss of the backup starting air supply.
This is a Severity Level IV violation (Supplement II).
Supply System Response Purchase Requisition number 103922 was processed to procure spare relays for the air start system in February of 1983. This purchase requisition did not specify gold contacts for the K17 relay. Existing Plant Procedure number 13 (1.3.13) requires review of the technical requirements by the Plant Techni-cal Staff and their supervisor and Plant Quality Assurance. The Plant QA group identified the fact that the K-17 relay required gold contacts and docu-mented the fact that technical requirements were being overlooked in memorandum dated June 28, 1983. Therefore, the existing plant process functioned pro-perly in that an improper procurement was identifieu and stopped. In review-ing the process it is evident that the technical review needs strengthening.
)

o Notice df Violation Page 2 of 2 Cause of the Deficiency The cause of this deficiency was:
: 1) The result of inadequate application of the Purchase Requisition process as described in Plant Procedure Manual (PPii), Volume 1, Section 3, Proce-dure No. 13 (1.3.13), " Material, Equipment, Parts and Supplies Procurement.
Revision No. 10 (Section 5.b) of this procedure, under responsibility of originator, states, " Adequate technical requirements shall be provided to precisely identify the item and its critical characteristics."       Informa-tion regarding the need for gold-plated contacts existed upon the revised Bill of liaterials attached to Project Engineering Directive (PED-218-E A332), which was located within the Startup Building's (#88) Controlled Files and which existed at aa additional location withia the CVI Files of the Architect / Engineer. However, the reviewers did not use the Bill of Materials.
: 2) Furthermore, it is the responsibility of the Purchase Requisition origina-tor's supervisor to " verify accurccy and completeness of requisition by determining the intended use of materials is satisfactory."       (1.3.13.2.b.4)
This verification was apparently performed by observation of the original specification / manual, which did not incorporate the modified Bill of Mater-ials at the time.
: 3) Additionally, the requirement exists (1.3.13.3.a) for the Plant Technical personnel to " review PR's indicated in 1.3.13.5.a.2.c.1 for proper quality class and adequate technical and quality requirements." This review was also performed without referring to the revised Bill of Materials within the Controlled Files.
Action to Preclude Repetition Corrective action to preclude inadequate technical requirements being speci-fied on purchase orders include the following.
: 1. Plant Procedure No. 13 (1.3.13) has been revised to specify the use of the controlled Bill of Materials when revie ing purchase regt.isitions.
Plant Technical Staff has been made directly responsible for this review.
: 2. Plant Technical Staff have been re-trained in the process of Purchase Requisition review.
: 3. Other 50.55(e) actions will be sampled to determine if similar problems exist.
Date of Full Compliance The sample will be complete by October 21, 1983.}}