ML17285A887

Rev 0 to Commercial Grade Dedication Project for Wppss Contract C-30298.

ML17285A887
Person / Time
Site:	Columbia
Issue date:	08/14/1989
From:	Craig W, Hanna G, Shulman M CYGNA ENERGY SERVICES
To:
Shared Package
ML17285A886	List: ML17285A885 ML17285A887
References
89162-TR001, 89162-TR001-R00, 89162-TR1, 89162-TR1-R, NUDOCS 8912140270
Download: ML17285A887 (24)

Text

Job No.AAO-89162 Report No.89162-TR001 Revision: 0 Date: 8/14/89 COMMERCIAL GRADE DEDICATION PROJECT FOR IVASHIYGTON PUBLIC POWER SUPPLY SYSTEM CONTRACT NO.C-30298 Prepared By: Geo Han Reviewed B ichael N.hulman ate Ffr$8f Date Approved By: 9~6'.5ai 8 Id rig William E Craig I~Date Cygna Energy Services 2470 Windy Hill Road, Suite 446 Atlanta, GA 30067 August 14, 1989 S912140270 891130 PDR ADOCK 05000397 G FNU IIIIIIIIIIIIIIIIIIIIIIIIIIIIII 2(86.00 1.0

SUMMARY

Cygna Energy Services engineers have evaluated fifty (50)Supply System selected commercial grade dedications as performed by current WNP-2 Procurement Requirements Evaluations (PRE's)The Supply System Evaluations were augmented, as necessary, in order to ensure that the procured items are adequate for their installed application(s).

The standard of acceptability was considered to be EPRI-NP-5652, (NCIG-07)and the Final Draft"Guideline for the Technical Evaluation of Replacement Items in Nuclear Power Plants" (TERI).Of the fifty items evaluated, all but one (1)were determined to be adequate for installation, with the incorporation of additional certification in some instances.

Nine (9)items were found to be adequate as dedicated by existing Procurement Requirements Evaluations.

Another eleven (11)items were considered adequate through added documentation of post receipt and installation testing.Fourteen (14)others could be reclassified by the Supply System as non-safety related and therefore would not require dedication.

An additional fifteen (15)items could be upgraded to current guideline requirements by the Supply System performing additional Commercial Grade Supplier audits and/or obtaining certifications verifying critical characteristics.

Cygna recommends that the Supply System perform audits and obtain certifications, as indicated, for these items.-One item was determined to be inadequately dedicated due to incomplete determination and verification of critical characteristics and the authorization of its unrestricted use.The Supply System technical approach for dedicating safety related items was found to be generally sound.However, the documentation requirements of current guidelines were not met in many cases.Recent program enhancements by the Supply System should provide for improved vendor selection and documentation in the future.IIIIIIIIIIIIIIIIIIIIIIIIIIIIII 204b 00 Commercial Grade Dedication Project Washington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0 ywppss~891629inalrpt.2 2.P OESCRIPTION OF SCOPE PERFORMEO Cygna Energy Services engineers evaluated 50 Supply System selected commercial grade dedications in order to ensure that the items, when installed, would'be adequately dedicated for their application.

The commercial grade dedications were performed by the Supply System in accordance with Procedure No.1339, Rev.2 or, earlier.The review first attempted to determine whether the dedications were consistent with USNRC Generic Letter 89-02, EPRI-NP 5652,"Guideline for the Utilization of Commercial Grade Items in Nuclear Safety Related Applications (NCIG-07)," EPRI, Final Draft,"Guideline for the Technical Evaluation of Replacement Items in Nuclear Power Plants" draft, ASME Section III, ANSI N422 and associated daughter standards, 10CFR50.49, USNRC Regulatory Guide 1.97 and other standards or guidance documents as appropriate.

These other documents included but were not limited to'USNRC I 4 E Bulletins and Notices, Inspection Reports and Notices of Violations.

The Supply System FSAR, QID's, specifications, drawings and procedures were also utilized.The evaluation process is described more fully in Cygna Work Instruction 89162, No.1 prepared specifically for this scope (see Appendix A).When the dedication documentation was not complete, Cygna attempted to develop documentation to meet the above guideline requirements.

These actions included vendor contact to obtain additional certification,'requested specific audits of commercial grade suppliers and'researching Supply System documents (e.g.FSAR, Technical Manuals, QID's, EQE memorandums, drawings and procedures3 Classification of the item was also reviewed.If the item could be reclassified as non-safety related, Cygna recommended the Supply System do so and thereby preclude the need for dedication.

In some cases the item was supplied by an ESL vendor and consideration of future procurements as a QCI item was suggested.

IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercial Grade Dedication Project Washington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rey.0 2'wppmi89162enalrpt 2

3,P RKSULTS AND DISCUSSIONS The Supply System Plant Technical Procurement Review Evaluation Procedure, PPM 1~39, Revision 2 and earlier, resulted in some dedications that were quite acceptable,and generally in accordance with current NRC and EPRI guidelines.

However other dedications required the specific reference to other Supply System procedures and documents in order to verify critical characteristics.

In many cases, vendor certjfications were obtained or determined to be available and these should be obtained by the Supply System and added to the procurement documents to meet current EPRI dedication guidelines.

Forty percent of the items could be rechssified.

The evaluations of the dedications were accomplished in several steps based on the jnjtja]assessment of the completeness of the existing evaluation packages.Each step established the acceptability of a particular population of the 50 items.These steps were discussed in Section 2.0 and the results are discussed below as well as detailed in Table 1.The complete evaluations for all items were previously submitted to the Supply System.3.1 Adequately Dedicated Commercial Grade Items Qf the fifty (50)items evaluated, nine (9)were determined to be safety related and to have been adequately dedicated by the Supply System.In many cases, these items were relays or switches obtained from approved vendors of the Supply System that were functionally and seismically tested after receipt.These items are specifically identified in Table 1 with a"I" in the right-hand column.In these cases the dedication was specific in identifying verification requirements.

3.2 Post Receipt Documentation Augmented Another eleven (11)items were fo'und to be dedicated based on additional credit taken for Supply System documentation and/or procedures used in the verification of critical characteristics.

Some'>f these item's critical characteristics were verified through Supply System post-installation testing, and availability and operation testing as described in IEEE 387-1977 (for diesel generators)

The documentation of that verification process was not included in the dedication.

These items are designated with a"II" in the Table 1.39 Additional Documentation Required Sixteen (16)items could be dedicated to current guidelines through audits and/or further certification by the vendor.In these cases, critical characteristics of the item or like-for-like certification by the vendor would augment the Supply System dedication.

These items are designated with a"III" in Table 1.Six (6)certifications were obtained from Supply System audited vendors and should be added to the procurement docujnentatjon files.c'...:;."'

0.L L3 BHIIIHIIIIIIIIIIIIIIIIlllll RW 00 Commercial Grade Dedication Project washington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0 gwppssh89162hf>nalrpt 2

Another ten (10)items were identified as being certifiable by the vendor or manufacturer.

In some of these cases the Supply System should audit the vendor or manufacturer for supply of commercial grade items.Audits of and certification by Cannon (PRE 300), SKF or ASI (PRE 359)and Amphenol or Almac (PRE 1217)are available and considered necessary to meet current guidelines.

Seven (7)of the items in this category could be procured as Class I items from the same vendor provided certification is obtained from the vendor.3,4+on Safety Related Items Another thirteen (13)items were determined to be non-safety related through Supply System documentation review or performance of an FMEA.An FMEA had been performed in some cases in the PRE and adequately determined the item to be not safety significant.

The remaining items required similar analysis which was performed as part of this sc'ope.The non-safety related items are designated by a"IV" in Table 1.3.5 Inadequate Dedication In one (1)case, PRE 0774 (designated by a'V" in Table 1)the Supply System dedication of an item was deemed inadequate.

In this case, Cannon connector pins P/N 030-9048-004 (Matcode 72105355)which are required to be manufactured to MIL-C-5015 were determined to be inadequate for installation as dedicated.

These pins were also procured as GE P/N 159C 4343P007.These items were procured for use throughout the plant from unaudited vendors or manufacturer.

Verification o'f MIL-C-5015 manufacture and electrical attributes would provide dedication of this item for installations specified by design basis documents.

llllllllllllllllllllllllllllll Commercial Grade Dedication Project Washington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0 Kwppssh89162hfinalrpt.2 Table 1 COHHERCIAL GRADE DEDICATIOM REVIEW SUHHARY 8/08/89 Eval Mo.HC HFG ESL P/M~Description OES ESL Vendor ESL Discussion 006 61112352 Air Monitor.Y 308-030 Comparator, Air spring based Honitor dl aphram Y Air Honitor Y Item is adequate for use.Certification obtained from ESL vendor to meet current guidelines.

Recomnend Class I procurement in future.0096 58162965 EHD"M 8364237 Punp, water right hand rotation 0147 58960752 EHD M 8367720 Oil lcvcl gage 0093 61113220-Robert Shaw M 7138 Gage prcssure 30IIIIQ 0-30 pslg Arthur Forsyth Co.Stewart N Coast Stcvcnson'ngines Stewart M EHD Stevenson IV Item Is odcquatc for use.Item is considered non safety related based on, FSAR.Item is adequate for use.Acceptable dedication with Dedication Basis from Evaluation No.1192 added as well as PPH 1.5.7 credit taken.IV Item Is adequate for use.Item used for local indication only and could.be reclassified as non-safety related.0171 81008221 lloodward Governor CG 9903-029 , (8271-01 I)Potenticeeter, assembly, motor operated Stewart Stevenson M Moodward Governor CG Item is adequate for use.Certification obtained from CG audited vendor to meet current guidelines.

0300 24208582 Cannon 0313 25107845 Setter gingham-Mi llamcttc Y 1514105 Screw cap socket hend throttle bushing sleeve M CA-Connector, 3106NR high tenor.10SL-4S ature TEC Y JT.K Supply, Electro Air, Connector llor td'etter Bingham-Nittamette N III Item is adequate for use.Certification by mfg.to HIL-C-5015 is required to meet current guidelines and shoutd be obtained for harsh environment applications.

Testing and inspections were performed.

III Item is adequate for use.Vendor supplied as Class I with certiflcatio Reconmend Class I procurement in future.1 L F I I IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercinl Grn(le De(licntion Project Washington Pul)lic Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0'nvppssh89162hfinnlrpt.2 t , j Table 1 COHHERCIAL GRADE DEDICATIOM REVIEN

SUMMARY

8/08/89 Eval Mo.HC HFG ESL.P/M Description OES , ESL Vendor ESL Discussion IV 0340 63401765 L'eeds I Morthrup 0359 43102304 SKF Fafner CG 067390.Sl idewire cover M 6202RS Bearing, Kaman 6202RSC3 single row Science 6202RSJEH radial ball Corp.M 202PLeeds 8 CG Morthrup N Bearings Inc.Bcsco, Rogers Hachinery Item is adequate for use.A FHEA performed indicated item would be non.safety related as installed.

Iten is adequate for use.Certificotion from OES or mfg.to verify tested configuration would meet current guidelines.

Recomnend future procuremcnt from OES.II, 0417 68600196 A SEA M RK225-Relay 052CP Fishback/~M ASEA (NI)CG Lord Elect.Relays qualified to NUREG Cat ll and instal'led under sound reasons to the contrary position.Dedication acceptable under such conditions, bvt should be re-reviewed after environrncntal testing is conplcted.

IV 0422 66900232 l.eeds 8 CG 036292 Comnutator Morthrup 0462 56411523 Hsrotta M 4400172 0-ring Scientific/

1458/Parker CG 2-145 Haretta Scien-tific Leeds f CG Northrup M Air Oil Prod.Item is adequate for use.FHEA performed in PRE determined item is not safety significant.

Item adeqvate for use based on like for like position.Parker P/M establishes critical characteristics.

Obtain certification from Parker (audited CG suppl I er)0544 68409306 General Electric, Halvcrn, P.A., Puerto Rico M 262A7065.Switch, SBH General Y Gencrol P001 control, 4 Electric Electric, pos., 10 San Jose contacts 0489 65002063 Leeds 8 CG 017970 Hotor, chart-.Leads S, CG Leeds 8 CG Northrup Northrup Northrup I Adeqvately procured as Comnerciat Grade Item from CG ESL vendor with certification to seismic test report and installation vcrlfication of operabilIty.

I Adequately procured as Comnerciat Grade Item from ESL vendor with certification.

FHEA pcrformcd in cvalvotion.

llllllllllllllllllllllllllllll Commercial Grade Dedication Project'ashington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rcv.0 bvppssh89162hflnalrpt.2 Table 1, COHHERCIAL GRADE DEDICATION RFVIEIJ SUHHARY 8/08/89 Eval No.HC HFG ESL P/N Description OES ESL Vendor ESL Discussion 0574 43902691 ingersol-Y 10BH.69 Retainer, Stewart N Coast Rond rotor pinion Stevenson Engines CG Item is adequate for use..Acceptable dedication with dedication bases from Evaluat.ion No.1192 added as well as PPH 1.5.7 credit taken.0612 61900132 Ba l l ey Controls 0633 68093604 Allen Bradley Y 6170K62G Sl idewi re;0700 resistance assy N 800T-Cover, N156 locking, for push buttons Boiley Nickcliff and CA~AHFAC Item is adequate for use.Certification obtained from ESL vendor to meet current guidelines.

Reconmend Class I procurement in future.~rv Item is adequate for use.FHEA applied and part.was determined not safety related based on having no functional" requirements.

0645 54502231 ASCO Y 306 154 Kit, Viton valve rebui l ding 0668 68600525 Potter 4 CG 27E006 Terminal, Brief I aid socket relay solder General" Y 175A9216-Electric P001 0637 54300470@hi tey-CG SS-1RS6 Valve, regulating and shutoff 1 General Electric Seattle Valve and Fit'ting, Inc.Steam Supply I Rubber Co.Y Radar Electric, General Electric, San Jose Item is adequate for use.Item has generic safety related application.

Recomnend future procurement as Class I.Use of Comnerciat Grade Items determined to be adequate by Supply System EOE memorandua.

Procurement from ESL vendor recomnended to meet current guidelines.

III Adequately procured as Cermerclat Grade Item from ESL and CG audited vendors.Certification from Patter Bruaf leld recomnended to meet current guidelines.

s.EL IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercial Grade Dedication Project Washington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0 bvppssh89162hfinalrpt.2 Table 1 CONHERCIAL GRADE DEDICATION REVIEN SUNNARY 8/08/89 Eval Ho.HC HFG ESL P/H Description OES ESL Vendor ESL Discussion 0699 56402773 Parker CG H 0-ring silicone rubber Northwest H Seals item is adequate for use.Source Inspection performed with COC from vendor and mfg.Evaluation should be changed to require COC from audited mfg.IV-0714 68409460 Leeds S CG Horthrup , 0762 68603871 Bailey Controls 0774 72105355 Cannon General N Electric 352832 Add P/H 617K90P01 54 now P/H 6125K63G 0700 030-09048.004 159C4343 P007 Switch, setpoint setting Relay, ASN Connector Pin;I Leeds 8'orthrop Bailey Y Bailey Controls Controls Radar GE, NJ CG Item is adequate for use.FHEA performed indicates item would be nonsafety related.Item is adequate for use.Acceptable CG dedication of exlstlng stock by post receipt testing and FHEA.COC required for future procurement from ESL vendor.Item is not adequate for use.Items procured from unaudited vendors to GE and Cannon P/H.Identification and verification of critical characteristics not accocpiished.

Use Is not controlled.

0831 65300662 HEI Peebles Y A14517-2 215 0796 54914111 Lent Co.N 2ABC Valve, air bleeder Brush, electric mo'tor R.A.Hiller Y Lent Co.H Stewart N HEI Peebles Y Stevenson Item ls adequate for use..Item is like for like replacement.

Procure from OES in future as Class I.Item is adequate for use..Certification obtained from ESL vendor.Reconncnded Class I procurement in future.IV 0852 52109981 END H 118752 Connector Stewart N Stevenson Coast Engines Item ts adequate for use.FHEA performed indicates item is not safety related.IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercinl Grndc Dedicntion Project WnslIington Public Power Supply Company Contract, No.C-30298 AAO-89162, Final Report, Rev.0'ovppssh89162hfinalrpt.2 Ihl iW MRS f88'55.'III'Ns sR$Isss GMs'sss:@is mes ass ass)tass Lass wiaa Table 1 COHHERCIAL GRADE DEO I CAT IOM REVIEM SUHHARY 8/08/89 Eval Mo.HC HFG ESLP/M Description OES ESL Vendor ESL Discussion 0900 68411140 General Electric, Malvern, P.A.Puerto Rico 0861 25213832 EHO N 26A 707-P001 Switch, SHG control, 4 pos., 10 contact.M 8032716 Nut, self locking Stewart Stevenson General Electric N Coast Engines CG Y North Coast M Electric Item is adequate for use.Acceptable dedication with dedication from Evaluation Mo.1192 added as well as PPH 1.5.'7 credit taken.I Acceptable dedfc'ation of Item by post-receipt testing.Future procurement could be through GE San J with POC required.0909 43902712 EHD M'456632 Retainer, rear rotor bearing airstart motor.EHO Item is adequate for use.Acceptable dedication with dedication basis from Evaluation MO.1192 added as well as PPH 1.5.7 credit taken.0915 68601610 Potter 8 CG CSJ38-grunfield 70010 Relay, CSJ i 38-70010.Radar Item is adequate for use.Certification from Potter Brunfietd would be necessary to meet current guidelines.

0936 42100905 EHD M 8077938 Coupl Ing, Stewart M EHO flexible,, Stevenson Item ls adequate for'se.Acceptable dedication with dedication basis from Evaluation Mo.1192 as well as PPH 1.5.7 credit taken.1035 54912550 EHO N 8447977 Seat and Stewart M EHO spacer kit.Stevenson M 0998 54914496 L imi torque Y 60-509.Manduheel, L lmi tor.Y Limi torque Y 0195-4 operator.quc IV Item Is acceptable for use.FHEA performed indicates item Is non safety related;and used for manual operation only.~Item is acceptable for use.Acceptable dedication with dedication basis from Evaluation Mo.1192 added as well as PPH 1.5.7 credit taken.IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercial Grade Dedication Project Wasliint,ton Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0'Kwppssh89162hfinalrpt.2-Table 1 COMMERCIAL GRADE DEDICATION REVIEN SUMHARY 8/08/89 Eval No.HC MFG ESL P/N Description OES ESL Vendor ESL Discussion IV 1059 42100240 Leeds 8 Northrup CG 137117 Bel t, nunc r i ca l printing.Leeds F, CG Northrup Item is adequate for use.FHEA performed indicates item is non safety related.1079 68410076 General Electric, Halvern, P.A.Puerto Rico N 16SB1CA Swi tch, am-General 7x2 meter type Electric SBI.Y North Coast N Electric Adequate dedication of Item by post receipt testing.Future procurement could be through GE San J with POC required.1102 54104512 Dragon Valves Y 19-11942-Spring, 72 Poppet for check valve Dragon Valves Item is adequate for use.Purchased Class I with ASME and Part 21 Certification.

No dedication required.Future procurements should be Class l.1126 58107742 John Crane Y D-4562-Near ring on 022-9200 mech.seal 1132 60805892 Air Honl tor Y Special Convertor John Crane N Portland, OR Air Honitor Y IV Item is adequate for use.FHEA performed and indicates item is non safety related significant.

III Item is adequate for use.Certification obtained from ESL vendor to meet current guidelines.

Recomnend Class I procurement in future.1155 42103621 Dodge N 40 Chain Neman Bearing IV'tem Is adequate for use.FHEA performed and indicates item is not safety related.1178 42001701 EHD N 8069019 Gear,~Camshaft Drive Stewart N EHD Stevenson Ii Item Is adequate for usa.Acceptable as original'ly evaluated with additional credit taken for PHH 1.5.7 for fit and function verification.

IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercial Grade Dedication Project Washington Public Power Supply Company Contract.No.C-30298 AAO-89162, Final Report, Rev.0 10 bvppssh89162hfinalrpt.2 Eel SWAI 5IBROSI'OeLQI M5L QehL'same laaaau iaaeao macaw Table 1 COHHERCIAL GRADE DEDICATION REVIEM SUHHARY 8/08/89 Eval No.HC HFG ESL P/N Description OES ESL Vendor ESL D I scuss I on 1192 43902964 EHO N 8237400 Shell, Bearing upper and lower hal f Stewart Stevenson N EHO Item is adequate for use.Acceptable as originally evaluated with additional credit taken for PHH 1.5.7 for fit and function verification.

217 74202324 Amphenol N HS3102AI 4SSS Receptacle

'ox solid shell HIL-.C5015 General Electric Y ALHAC Item adequate for use when brought to Supply System Proc.Reg.Eval.1217.Supplier(s) should be audited and placed on CG Supplier list to meet current requirements.

1231 58602635 EHD N 9093027 Tube Assembly Stewart Stevenson N EHO Items adequate for use.Acceptable dedication with dedication basis from Evaluation No.1192 added as well as PPH 1.5.7 credit taken.1319 68404533 General N 12PJV11AF Relay-General Y North Coast N Electric I A Instantaneous; Electric Electric Voltage, i 115 VAC Acceptable dedication of item by post receipt testing.IV 1354 56508270 Hiller Fluid Power N 090.Seal, tube ES006.500 end Hiller Fluid Power Item is adequate for use.Letter in Supply System file considers items not safety significant.

1595 40300190 General Y Electric, San Jose 175A8230P Tubing, 007 Q.375" shrinkable GE Y General Y Electric,'an Jose Adequately procured from ESL vendor as conmerciai grade item with certification to verify critical characteristics.

1736 58405235 York N 261540500 F I l ter, 6~Refrig.York N IV Items Is adequate for use.FHEA performed indicates item is not safety related.III 1933 56413560 Valcor Y SIOICB21 O.R Ing Valcor Item Is adequate for use.Certification should be procured from Valcor to provide adequate harsh environmental qualification.

Illlllllllllllllllllllllllllll Commercial Grade Dedication Project Washington Public Power Supply Company Contract No.C-30298 AAO-89162, Final Report, Rev.0ovppssh89162hfinalrpt.2 Table 1 COHMERCIAL GRADE DED I CAT IOH REVIEM SUHHARY 8/08/89 Eval Ho..MC HFG ESL P/H DescriPtion OES ESL Vendor ESL Discussion 2324 68400605 General Electric H 175A101 Sui tch, General Y General 3P002 Pushbutton Electric Electric, San Jose Item adequately dedicated by PQC certification and prior seismic testing.L====a~ra IIIIIIIIIIIIIIIIIIIIIIIIIIIIII Commercial Grade Dedication Project Washington Public Power Supply Company Contract No.C-30298 AAO-89162, I inal Report, Rcv.0 12 bvppssh89162hfinalrpt.2 ATTACHHEHT 2 Supply System Description of Sample Selection and Population of Commercial Grade Items Discussion The Supply System has a population of 9730 commercial.grade items that are defined's acceptable for use in safety related applications or on safety related plant equipment.

This population is composed of items with a quality class of 1C (Commercial) procured prior to Hay of 1986 and CG (commercial grade)procured since Hay of 1986.53%of the existing commerc.ial grade items are 1C and 47%are CG (see Exhibit 1).The commercial grade items population'an be categorized as follows: Spare Parts-items with a specific component usage intended, 39%of population and Commodities

-items without a specific component usage intended, 61%of population Hithin each of these categories are items of higher significance or more complicated devices and items of lower significance or simple devices.(See Exhibit 2 for Listing of items considered to be of Low Significance.)

The Supply System commercia'1 grade items listing was reviewed to see how many items in each category (Spare Parts vs Components) were of Higher Significance.

This review concluded that: 23%or 2279 of the 9730 total population were higher significance items.21%or 2019 of the higher significance items were spare parts.15%or 1466 of the higher significance items were quality class CG (post Hay 1986 procured)spare parts.See Exhibit 1 for a summary of the Commercial Grade Items population distribution.

~mme I ze A sample size of 50 was judged to be appropriate.

Based on the binomial probability distribution, this sample size assures a 95 percent acceptance coefficient for the population at a confidence coefficient in excess of 90, percent, given that no rejects are identified within the randomly selected sample.However, a negatively biased sampling methodology.was used (see"Sample Selection" and"Sample Skew" below), which results in an increased coefficient of confidence.

COMMERCIAL GRADE ITEMS 0 QUALITY CLASS CG-(SAFETY-RELATED) 1C (PRE-5/86)

TOTAL SPARE PARTS..2574 27%" (1466 15%)1221 12%(553 6%)3795 39%(2019 21%)COMMODITIES 1971 20%(86 1%)3964 41%(152 1%)5935 61%(260 2%)TOTAL 4545 47%(1552 16%)5185 53%(705 7%)9730 100%(2279 23%)()-HIGHER SIGNIFICANCE ITEMS"-50 SAMPLE CHOSEN FROM THIS POPULATION EXHIBIT 1 I AN (P)I F~ID'-RINGS BOLTS, NUTS,,MASHERS ETC.GASKETS, PACKAGING FUSES, FUSE BLOCKS-ELECTRONIC PIECE PARTS~TUBE/PIPE FITTINGS LUGS CONDUIT, FITTINGS, BOXES LUBES, SOLVENTS, ETC.LANPS-TAPES/NARKERS STEEL HISC 230 751 607 2715 (RESISTORS, CAPACITORS ETC)608 206 979 87 120 67 266 (RAGS, PENS, CHART PAPER, ETC)TOTAL 7451 EXHIBIT 2 Following the 6/28/89 Enforcement Conference on the 10 commercial grade items the Supply System selected a sample of 50 commercial grade items to be review-ed by CYGNA.The sample of 50 was chosen from the-sub-population'f Quality Class CG Spare Parts (-see Exhibit 1).This sub-population has by far the most higher significance items and consequently represents a more conservative sample than a random selection from the entire population.

The higher significance items make up 23'/(2279)of the total population of 9730 items, whereas the higher significance items account for 82%(41)of the 50 sample specimens.

In order to bias the sample towards uncovering potential rejects, a modified sampling process was used instead of a pire random process.The process used to select the sample was as follows: A computer Listing of'Quality Class CG (post Hay 86)spare parts was used to define the items under consideration.

This listing was in order of the Supply System procurement evaluation Log No.-lowest number or oldest to highest number or newest.This report contained 87 pages.Starting with page 1 a single item was chosen at random by matcode (Supply System material identification number)which precluded any.prejudice in the selection.

Following this selection a single item was similarly selected from page 2, etc.This process was used to select the first 38 items.Since this was resulting in a'sample skewed towards older evaluations, we began to skip pages foi.the remaining sample item selections.

On the pages not skipped, the remaining 12 items were also"blind" selections based on matcode.Additionally, as similar items repeated in the sample selection process they were rejected and another item chosen to give a wider, more comprehensive test of the Supply System dedication process.This sampling process provided a more conservative test of the population than a truly random selection.

The sample.was taken from a'ub-population containing the highest percentage of higher significant items and was skewed towards older evaluations (82%prior to 1/1/88)as is demonstrated by Exhibit 4.In fact, 98%of the sample items had been evaluated prior to the June 1988 issue of the EPRI NCIG-07 guidance.Exhibit 3 summarizes the Sample Selection.

CG ITEHS SAMPLE SELECTION TOTAL CG ITEHS 9730%OF POPULATION COHHODITY/SIHPLE CG ITEHS-7051 REHAINING CG ITEHS 2279 77%23%CYGNA REVIEW SAHPLE-50 ITEHS SELECTED 9 SIHPLE 91 SIGNIFICANT ITEHS 18%82%BASED ON HIL 105D A.SAHPLE SIZE OF 50 MAS SELECTED TO PROVIDE 95%CONFIDENCE.

SAHPLES MERE"BLIND" SELECTED FROH A LISTING OF CG ITEHS BY EVALUATION NO.SELECTED 1/PAGE FOR 38 PAGES OF 87 PAGE REPORT-THEN SKIPPED PAGES.ALSO ELIHINATED SOME REPEAT SIHPLE ITEHS.RESULT I NG SAHPLE MAS SKEWED TOWARDS OLDER DEDI CAT IONS AND LESS S IHPLE ITEHS.EXHIBIT 3 C~~SAMPLE CHRONOLOGICAL DISTRIBUTION 3-86 4-86 1-87 2-87 3-87-4-87 1-88 2-88 3-88 4-88 1-89 CALENDAR QUARTERS~4 EXHIBIT 0 O Res 1 An 1 i Following the CYGNA Analysis the Supply System re-evaluated the sample size to provide assurance that the conclusions were statistically correct.We found that for the population under consideration a sample size of 59 with no rejects identified in the sample would assure a population acceptance coefficient of 95 percent at a 95 percent confidence level (commonly referred to as 95/95 sampling constraints), based on a randomly selected sample.The confidence level corresponding to a sample size of 50 (at the same 95 percent population acceptance coefficient) would be 92 percent, if the sample were selected randomly.However, since a negatively biased sampling methodology was used, the confidence level provided is actually higher than 92 percent.The 10 items reviewed by the Staff and the Supply System coupled with the CYGNA review of an additional 50 items has been determined to be an adequate sample size, especially in light of the sample bias towards the older and/or more significant items.i i nal D In May of 1986, as part of the programmatic improvements in procurement, the Supply System committed to re-evaluate the procurement requirements for all items before allowing procurement.

Since that time the Supply System has re-evaluated 10316 (49%)of its spare parts and 17868 (33'L)of its total inventory.

During these reviews some problems were noted and were documented, as nonconformances.

The total nonconformances written was approximately 20, , and none were safety significant or reportable.

Since our procedure revisions in May of 1989 we have re-evaluated additional items without any significant findings.These re-evaluations provide us with additional confidence that our past practices, although not thoroughly documented have not resulted in a significant safety concern for our existing inventory.

See Exhibit 5 C The Supply System concludes that there is reasonable assurance the inventory of commercial grade items is acceptable for use in safety related applications.

The Supply System is committed to upgrade the procurement requirements/dedica-tion requirements for all commercial grade items prior to the next procurement.

In light of the continuously evolving nature of this area we believe this is a reasonable and responsible plan of action and in accord with the NUMARC'initiative.

SUPPLY SYSTEN RE-EVALUATION DATE DECEMBER.1986 NO.SPARE PARTS 15832 NO.RE-EVALUATED 697 (0%)TOTAL INVENTORY ITENS 49095 NO.RE-EVALUATED 3223 (6%)HAY 1989 20633 9592 (46%)53953 15903'29%)NOVEMBER 1989 21000.10316 (09%)17868 (33%)RESULTS DEC 1986-NAY 1989-4801 NEM SPARE PARTS 9791 RE-EVALUATED SPARE PARTS HAY 1989-NOV 1989-371 NEW SPARE PARTS 353 RE-EVALUATED SPARE PARTS EXHIBIT 5 0)4 r