IR 05000312/1988002: Difference between revisions

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{{Adams
{{Adams
| number = ML20151W087
| number = ML20246P038
| issue date = 07/25/1988
| issue date = 05/12/1989
| title = Insp Rept 50-312/88-02 on 880104-0309.Weaknesses Noted. Major Areas Inspected:Past & Present Procurement,Matls Control & Warehouse Activities Before Restart
| title = Discusses Insp Rept 50-312/88-02 on 880104-14,0210-12 & 0307-09.Violations Noted.Advises That Violations Demonstrated Lack of Mgt Control Over Certain Aspects of Procurement Program.Enforcement Action Not Necessary
| author name = Brach E, Jacobson J, Mcintyre R, Wagner W
| author name = Martin J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
| addressee name =  
| addressee name = Firlit J
| addressee affiliation =  
| addressee affiliation = SACRAMENTO MUNICIPAL UTILITY DISTRICT
| docket = 05000312
| docket = 05000312
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-312-88-02, 50-312-88-2, NUDOCS 8808230278
| document report number = EA-89-058, EA-89-58, NUDOCS 8905220065
| package number = ML20151W083
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 20
}}
}}


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  . ;pa m g'o  UNITED STATES 8  p, NUCLEAR REGULATORY COMMISSION s i, ej  REGION V g 1450 MARIA LANE, SulTE 210
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  %'+, + n * * * 4 0  WALNUT CREEK, CALIFORNIA 946964368 M AY 1 2 1989 Docket NO. 50-312 License No. DPR-54 EA 89-58 i
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Sacramento Municipal Utility District   l
  , , ENCLOSURE 2 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATI0ii DIVISION OF REACTOR INSPECTION AND SAFEGUARDS
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ATTN: Mr. Joseph F. Firlit Chief Executive Officer, Nuclear 14440 Twin Cities Road Herald, California 95638-9799 Gentlemen:
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SUBJECT: NRC INSPECTION REPORT NO. 50-312/88-02 This refers to the NRC inspection conducted on January 4-14, February 10-12, and March 7-9, 1988 at the Rancho Seco Nuclear Generating Station. By letter dated August 18, 1988, the above referenced inspection report was sent to yo As described in the report, it was discovered during the inspection that certain of your past activities related to procurement and material control apparently had been conducted in violation of NRC requirements. After the inspection, but befoce we authorized you to restart the reactor in March 1988, we verified that you had initiated comprehensive corrective action In addition, since restart of the reactor, we have been substantially setisfied with the implementation of your program for procurement and material contro The violations identified during the NRC inspection involved: (1) failure to properly dedicate several commercial grade items used in safety-related ,
Report No.:  50-312/88-02 Docket No.:  50-312 Licensee No.:  DPR-54 Licensee:  Sacramento Municipal Utility District Post Office Box 15830 Sacramento, California 95852 Facility Name: Rancho Seco Nuclear Generating Station Inspection Conducted: January 4-14, February 10-12, and March 7-9, 1988 Inspectors:  .
applications; (2) failure to adequately evaluate vender quality assurance '
R. P. McIntyre, Team Leader, NRR V
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25f66 Date
  /  72 Sky J.BfJfo5sp6,ElectricalEngineer,NRR  Date SP WrWL h W. J. Wagner, Project E7Fgineer, fV 7 I zs/sS Date '
Consultants:  T. Tinkel, Sonalysts, In Accompanying Personnel: U. Potapovs, NRR Approved by: / n eb E.''killiani Brach/,4 ranch Chief 7hf[f Aat4 Vendor Inspection Branch i
8808230278 880818 PDR ADOCK 05000312 G  PNU    l
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An announced team inspection at the Rancho Seco Nuclear Generating Station was conducted by the NRC Headquarters Vendor Inspection Branch (VIB) to review the licensee's past and present procurement, materials control, and warehoust activities before the restart of Rancho Sec RESULTS:
The inspection indicated considerable weakness in the procurenent prpcess, specifically the dedication of commercial grade items for use in safety-related dppliCations, and the auditing and placement of vendors un the approved supplier list (ASL). The inspection findings include: (1) failure to properly dedicate and provide documentation for several coninercial grace items procured for use in safety-related applications (these items were accepted on the basis of a
''like-for-like" comparison of part number without adequately evaluating their suitability for use in safety-related applications); (2) failure to impose the requirements of 10 CFR Part 21 on several vendors where certifications to nuclear specifications were required; and (3) failure to acequately evaluate the vendor's quality assurance (QA) programs before placing the vendor on the approved supplier list (ASL). Also, the licensee accepted certificates of conformance (C of Cs) for commercial grade procurements from vendors not on the ASL without verifying their validit I
 
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1. PROCUREMENT OF MATERIALS Procedure Review As part of the inspection, a review was conducted of the SMUD procedures that delineate requirements applicable to the 9,rocurement of items and services at Rancho Sec dancho Seco Administrative Procedure, RSAP-401, "Preparation and Processing of Purchase Requisitions," provities instructions for the preparation, review, and processing of purchase requisitions. This procedure only opplies to the initial purchase of items and services, including spare and replacement parts. Standard stock items nonnally carried in the warehouse are recorded in accordance with Materials Management Procedure, MMP-002 RSAP-0401 defines three types of procurenents : Type 1 is the procurement of items associated with the maintenance and minor modification of existing plant systems and equipment, Type 2 is the procurement of items associated with major modifications of plant systems and equipment, and Type 3 is nuclear fuel purchases. After all of the information is entered on the purchase requisition, plant procurement issues a purchase order in accordance with procedure MMP-0022, "Procurement." MMP-0022 directs Procurement Engineering to review the purchase requisition in accordance with MMP-0021, "Technical and Quality Determination for Procurement Documents."
 
MMP-0021 outlines the methods used by Procurement Engineering for establishing technical and quality requirements for inclusion in procurement documents. Three classes of materials are defined by this procedure: QA Class 1 is for all items or services for safety-related applications, QA Class 11 is used for non-safety-related items or 'ervices in which additional quality assurance is  I required; and QA Class 111 is used for the procurement of all other items and services. Procurement Engineering determines the quality class of the item to be ordered by referencing the master equipment !
list (MEL) and by reviewing ap specifications, as necessary. plicable drawings, A procurement levelcodes, is thenand material selected i
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in accordance with MMP-0026, "Four Level Procurement System" on the !
specification requirements that must be applied, the qualification of the supplier being considered, and the acceptance methods used to verify the item's quality characteristic MMP-0026 describes the four-level procurement system for procurement of items and services, that are QA Class 1 or are subject to SMUD QA program requiren.ents. Level I is applicable to items for safety-related applications in which procurement must meet procurement  i specification This method requires current qualification of the l supplier's QA program. Items may be accepted on the basis of this approved QA progrem, a C of C, a source inspection, and/or a receiving l
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, , inspection. Level II is applicable to items for safety-related applications in which procurement must nwet a previous (original)
procurement specification. This method also requires current qualification of the supplier's QA program and also allows acceptonce of the items on the basis of a combination of C of C, a source inspec-
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tion, and/or a receiving inspection. Level III is applicable to items for safety-related applications in which procurement is made by the supplier's part number, drawing, specification, or other associated documentation. This method does not require qualification of a supplier's QA program as acceptance is based on a combinatJon of source inspections, receiving inspections, and/or specific inspections or test Level IV is applicable to items manufactured to industry or comercial standards that satisfy the definition of "commercial grade" per 10 CFR Part 21. This method does not require quhlificat on of the supplier s QA program as acceptance is based on receipt inspection or test to verify that characteristics important to the item performance have been met. Level IV procurements require that a quality-related item evaluation in accordance with SSAP-0005 be completed for items designated as comercial grade. The irspectors found that SSAP-0005 had been deleted and replaced with RSAP-0405,
"Quality Related Item Evaluation." This outdated SSAP was also referenced in two other current procedures, MMP-0026 and MMDI-C010
"Stock Material Reverification Program."
 
RSAP-0405 defines the methods used to determine if items requested for purchase can be procured comercial grade and applies to Levei IV procurements only. The procedure requires the completion of form MTL-004, "Verification of Comercial Grade Status Checklist," and <
form MTL-002, "Quality Related item Evaluation." RSAP-0405 then  I requires evaluation of the safety-related functions the items perform or support and the specific characteristics necessary to ensure that the functions are accomplishe l t
Procurement Engineering is required to document on a receipt inspec- i tion cata report (RIDR) the method of inspection necessary to ensure l the proper functioning of the item. Critical characteristics, applicable codes and standards, restrictions on suppliers, and item applications are listed on the MTL-002. Nuclear Engineering then reviews the information documented to verify that the item will perform its intended functio Before a Level IV item can be issued for use in the plant, a comercial grade item dedication in accordance with RSAP-0706, "Dedication of Commercial Grade Items," is require RSAP-0706 defines the requirements for performing the dedication of comercial grade items. A work request for the use of a comercial grade item in a safety-related system is routed to Procurement Engineering, which issues a Comercial Grace Item Dedication (CGID).
 
Procurement Engineering lists on the CGID the application where the requested item will be used, the component description, the seismic classification, the environmental qualification (EQ) classification, and the Comodity Evaluation (CME No.) completed durin  A copy of the Quality Related item Evaluation (MTL-002) gisprocurcmen also attached to the CGID. The CGID is then routed to Nuclear Engineering,
 
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. . which evaluates. it for acceptability in accordance with NEAP-4205,
"Commercial Grade Item Dedication Evaluation" (CGIDE). Nuclear Engineering then performs a CGIDE on the basis of the CGID, the CME,.
the MTL-002, and design baseline documents. Nuclear Engineering  l also decides d. ether a separate EQ or seismic review is require l Once the CGIDE is approved, it is sent with the COW back to Procure-  i ment Engineering. The comercial grade part has ;ov been dedicated  i and can be issued for us In this procedure review, the inspectors noted a number of,. problem The first problem concerns the overall complexity and discontinuities in the commercial grade procurement process. So many procedures, forms, and evaluations are required that it is unclear who has what  i responsibility in determining part acceptability. It was apparent  I during the inspection that not only was the NRC inspector confused,  i but that many of the SMUD personnel did not understand their responsi-  i bilities in the proces l
 
Another problem concerns the fact that items procured under Level III  l of MMP-0026 do not undergo a formal dedication process. Although  l these items are not designated as comercial grade by this procedure,  j they are purchased from unqualified suppliers and are, in essence, commercial grade items that require dedicatio The most serious problem with the procurement procedures is the fact that both procedures RSAP-0405 (PP.5.2.3.3) and NEAP-4205 (PP.5.2.5.1.)
 
allow verification of critical characteristics by the use of a
"like-for-like" methodology. Specifically, once a part is found to have the same part number as the one being replaced, no further verification is requireo. This is an unacceptable practice because many material and manufacturing changes are made without changing  l part number If it is not verified that material and manuf acturing  ;
changes have not occurred, a component's qualification (both seismic  l and EQ) and its overall suitability for use in safety-related  l applications are in question. Many of the items procured at Rancho Seco and accepted on the basis of a "like-for-like" methodology are in this a tegor Procedure RSAP-0700, Rev. O, and Changes PCN 1, 2, 3, and 4 identify  l certain comercial 9Me items for safety-related applications that SMUD exempts from the 10 CFR Part 21 requirement for dedicatio These items include bolts, nuts, screws, washers, cotter pins, and fasteners less than 1/4-inch nominal size that are exempt from dedication when they are used in safety-related application (Note: Other items, such as certain gaskets, packings, etc., are also included in the exemption list in this procedure.) This blanket exemption is of concern because the technical basis is not clear for ensuring that safety-related functions will not be affected when items such as fasteners are used in safety-related application SMUD stated at the exit meeting that they were going to review this comercial grade item exemption list and take corrective action to implement some form of generic dedicatio *
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The NRC inspectors found one instance in which SMUD personnel failed to comply with their documented procedural requirements. Discussion with procurement and material control personnel revealed an instance in which a comercial grade item was issued from Warehouse A without the required CGID. Stores Issue / Reservation Request (SIRR) No. 87024129, dated November 27, 1987, issued 14 in-line comercial grade filters (Material Stock Code 109700) for use'in a QA Class 1 componen RSAP-0706, Section 4.2, states, in part, that "Dedication at Rancho Seco occurs after receiving inspection ano prior to is6suance of the item for installation," and specifically in Section 5.4.3 %"Items purchased as Comercial Grade (Procurement Level IV) shall'not be issued on a SIRR that references a QA Class I or an EQ work request without an approved CGID." The inspectors found that warehouse personnel were aware of this requirement, and they issued the item without the CGID only after verbal instruction from licensee manage-ment. The inspection team found no other instances of verbal authorization to violate a program requiremen I In the PEAP interim report, SMUD outlined and described the enhancements and clarifications made to strengthen the procurement and material control procedures. The changes stated by SMUD address the concer and weaknesses identified by the NRC inspectors and, if properly implementeo, should resolve the past procedural procurement deficiencie SMUD also initiated a comprehensive training program to train all I appropriate personnel on the requirements of the new and expanded procedures for procurement and material contro Review of Procurement Packages To review the implementation of the Rancho Seco procurement program and the effect of past procurement practices on installed equipment, the inspection team requested 67 procurement packages. The procure-ment packages were selected after review of safety-related serializec work requests involving replacement parts from the past several year The packages selected were slanted towards those that were likely to contain parts that might have been purchased comercial grade. The requested packages cuntained the work request, the bill of materials, the receipt inspection documentation, and the applicable purchase order or requisition of material. Of the packages requested, the inspectors found that most of the parts were comercial grade and procured from unqualified suppliers. Most of these parts were ordered by part numbers that were verified before installation in the plan These part numbers were found to be the same as the original part numbers and this "like-for-like" mothedology served as the primary basis for the parts' suitability for applicatio No documentation existed that showed that an evaluation was ever performed of material and design changes that might have been made by the manufacturer since the original parts were procure The following comercial grade parts were procured and installed a'
without verification that material or design changes did not occur:
 
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* ' Work Request 88694 - a catalyst assembly for the hydrogen monitor was replaced with a comercial grade part from COMSIP. The hydrogen monitor is an EQ device, and no qualification documen-tation was received with the catalyst assembly. SMUD did not verify that no material or manufacturing changes were mad . Work Request 43196 - an Agastat relay was ordered comercial grade. No seismic qualification was received. SMUD did not verify that no material or manufacturing changes ceere mad '
3. Work Request 88291 - a comercial grade K3 relay was ' ordere No seismic qualification was received. SMUD did not verify that no material or manufacturing changes were mad . Work Request 45631 - comercial grade circuit breakers for use in the "A" inverter in a vital bus were ordered. Functional testing was performed upon receipt without acceptance criteria being established (i.e., trip times were unknown). SMUD did not verify that no material or manufacturing changes were mad . Work Request 68932 - a comercial grade GE relay for the control logic to liquid sample valve SFV-7001 in the reactor sampling system was ordered. No seismic qualification documentation was received. SMUD did not verify that no material or manufacturing changes were mad . Work Request 82120 - comercial grade reactor coolant pump underpower protection Wilmar relays were ordered. No seismic qualification documentation was received. SMUD did not verify that no material or manufacturing changes were mad . Work Request 97391 - comercial grade Ohmite relays for the B normal bettery charger were ordered. No seismic qualification documentation was received. SMUD did not verify that no material or manufacturing changes were mad . The inspectors reviewed the recent procurement of 5000 feet of 5 kV cable for the safety-related nuclear raw water pump. This cable was purchased from an unqualified supplier, NSSS/Divesco, Inc., under the level 111 method of procurement. No quality assurance program or 10 CFR Part 21 requirements were imposed on this vendor; however, generic test data performed to IEEE standards 383 and 323/324 was requested. The quality of the cable was to be verified under the licensee's quality program by performance of independent testing by an outside laborator Upan receipt of the cable by the licensee, NCR 7220 was generated because no generic test data was submitted as required by the purchase order. The cable was conditionally released even though the independent laboratory testing specified on the RIDR had not been performed. Two days later, Revision 1 to NCR 7220 was written when the licensee discovered that one of the three reels of cable received was 15 kV and not 5 kV cable and that all three reels had been shipped on their sides. One week
 
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, , later on October 21, 1987, Revision 2 to NCR 7220 was writte At this time the licensee determined that the cable had never been independently tested and that this testing would be needed before the cable could be accepted on.a long-term basi Revision 3 to the NCR was written on the same day, and it deleted the testing requirements and accepted the cable on the basis of an analysis performed by Nuclear Engineerin Revision 4 was written the following day, and it deleted the barsh environment requirements from the analysis Upon questioning the licensee about the basis for the analysis, the licensee determined that the independent testing should not have been deleted because the analysis was based on test data received with a previous procurement that could not be used for the cable in questio This procurement violated two NRC requirement First, requesting test data to IEEE 383 and 323/324, no longer qualifies the cable as a comercial grade item as defined by 10 CFR Part 2 The provisions of 10 CFR Part 21 should have been imposed on the vendor. Secondly, cable procured from an unqualified supplier was accepted, installed, and declared operable without ensuring its suitability for use in the installed applicatio Qualification to the requirements of IEEE 383 could not be ensured as no traceability existed documenting the similarity of the purchased cable to any used in a previously performed tes This specific procurement also highlighted the fact that Level 111 procurements performed at Rancho Seco do not require a documented dedication process. Additionally, because of the complexity of the procurement process, it appeared that Procure-ment Engineering and Nuclear Engineering were not informed of each other's decision on this matte . Work Request 97071 - replacement parts for Bergen-Patterson hydraulic snubbers were procured from 1980 through 1985 via several purchase orcers. The licensee requested a C of C to nuclear specification (ANSI B31.7, "Nucl u r Power Piping")
without imposing 10 CFR Part 21 on Bergen-Patterson in the purchase oroer. The purchase order stated that these parts were comercial grade items, yet they did not meet the definition of commercial grade as delineated in 10 CFR Part 2 . EASRTP RI - 329 - four purchase oroers were submitted to different venoors for replacement parts for the instrument air l system. The material was ordered comercial grade and was l accepted on the basis of C of Cs to the manufacturers' specifica-tions without verification of their validity. The licensee did not perform any vendor audits, and none of the four vendors were on the AS . EASRTP RI - 058 - replacement lube oil coolers for high-pressure injection and makeup pumps for the nuclear raw water system were ordered comercial grade from Basco. A C of C to design
 
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, , specifications and testing requirements was used as the basis 1  for acceptance without verification of its validity. , Basco was not on the SMUD ASL, nor had the licensee perfonned any audit of Basco.
 
; Vendor Audit Program    l The inspectors .found that the former SMUD progrom for auditing. vendors was extremely wea Vendors who supplied safety-related and commercial grade items were placeo on the ASL solely on the basis of a desk audit of the vendors' QA manuals. There were no procedural requirements for implementation audits to be perfomed at the vendors'
facilities. SMUD recognized this' as a problem in 1987 as evidenced by Finding 87-20-22 of the QA vertical audit. SMUD's corrective action for this finding was to perform implementation audits of all vendors on the ASL by the end of 198 The NRC inspectors pointed out that SMUD procedures for approving suppliers still allowed procurements to be made with no established time limit for perfonning some form of verification or implementation audit before placing the safety-related. items in servic In the PEAP interim report, SMUD consnitted to revise their program and procedures to require that a QA program implementation evaluation be made before or during the "first significant" procurement activit Also, a requirement has been added for a formal source inspection of each procurement for any listed suppliers where no current objective evidence of satisfactory program implementation evaluation exist In summary, SMUD has stated that they have strengthened and clarified the process for supplier approva II. MATERIAL CONTROL AND WAREHOUSING    l Review of the SMUD Material Control Process Reverification of Technical and Quality Documentation for Previously Procured and Currently Stocked Safety-Relateu Material As part of a response to LER 85-14. Revision 3, SMUD committed to perform a 100 percent reverification of all safety-related material in stock that was not procured using current procurement procedures. SMUD stated that the reverification program objective is to confirm that, on the basis of a documentation review, previously procured and currently stocked safety-related items meet all current SMUD procurement requirements. According to
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the Material Control Manager, any items that do not meet current l l
SMUD procurement requirements will be designated for non-safety I applications, scrapped, or submitted for engineering review to determine adequacy for a safety-related applicatio At the time of this inspection, SMUD was ensuring that reverifica- I tion was completed for previously procured coninercial grade items coded for safety-related applications before issuing any of
 
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these items from the warehous However, items previously procured and coded Quality Class I (safety-related) that were not identified as procurement Level IV or CG (commercial grade)
were being issued for installation regardless of whether the item had been reverified or .not. This prar.tice was discussed with the SMUD Material Control Manager who stated that SMUD considered reverification of Quality Class I (safety-related)
material was not a prerequisite for issuing from stock because SMUD had confidence in the past procurement program used for this niaterial . (Note: During the course of the inspection, SMUD developed a prcyram to reverify a sample of previously procured and currently stocked safety-related items to confirm SMUD's contention that reverification of Class I items before issue from stock was not required.)
 
During discussions with the NRC inspector, the Material Control Manager stated that to date about 200 commercial grade items in stock had been. reverified for safety-related applications and about 1000 Class I (safety-related) items in stock had been reverified. SMUD is scheduled to complete the reverification of all safety-related material in stock by September 30, 1988, as part of their LER commitmen . Green Tag Program One of the principal controls used by SMUD to identify Class I items (material coded for safety-related application) is the use of a green tag. The requirement for using green tags (i.e.,
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l SMUD accept tags) to identify material issued from stock for safety-related applications was instituted by a SMUD memorandum l i
of June 2, 1986. Some time elapsed until the requirement was l implemented by procedure in QAP-6. The current procedure governing the use of green tags is cuntained in RSAP 0701, Revision 0, dateo June 1, 1987. In the course of the inspection, i at least 3 physically different green tags were observe l Furthermore, green tags were found on stored items identifying the following quality class and procurement level situations:
' Class I, Procurement Level I (computer-generated tag)
  ' Class I, Procurement Level II (computer-generated tag)
' Class I, Procurement Level III (computer-generated tag)
* Class I, Procurement Leypl IV (computer-generated tag)
' Class I, Procurement Level 0 (cosputer-generated tag)
Class I, CG (handwritten' tag)
* Class I, no procurement level specified (handwritten tag)
* Class II, Procurement Level 0 (computer-generated tag)*
*The SMUD Material Control Manager stated that this tag is used for Appendix n items that are not Quality Class I (safety-related) but are important to safet .. q
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requirements before placing some vendors on the approved supplier list; and (3) failure to impose Part 21 requirements on certain vendor These violations demonstrated a lack of management control over certain aspects of your procure-ment progra l The NRC considered these violations a significant regulatory concern, and in the aggregate they represented a Severity Level III proble Normally, a civil penalty is considered for a Severity Level III violation or problem. However, in this case, a Notice of Violation or civil penalty will not be proposed because: (1) a program of identifying and correcting problems was implemented while the plant was in an extended shutdown related to prior poor performance; (2) NRC concurrence was needed prior to restart from that outage; (3) the the violations for the most part involved procurement activities performed under procedures and policies in effect prior to the shutdown; and (4) your corrective actions were responsive to the violations, and subsequent NRC have shown the corrective actions to be effective. In sum, enforcement action is not necessary to achieve appropriate remedial action. Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13, 1988), Section V.G.2, and after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support, I have been authorized to exercise l
' , ' SMUD Use of Non-Safety Fasteners in Quality Class I (Safety-Related) Job Applications A review of the issue histor control data base (NUCLEIS)fory Stock contained Code in the SMUD Number (SCN)material 8929 <
1 0 8905220065 890512    P~
revealed the following: (a) SCN 8929 is assigned for non-safety '
PDR Q
3/4" - 10 x 1 3/4" cap screws (note: Sch 8929 has now been superseded by SCN 103118), and (b) 50 of these cap screws were issueo against Work Request 12601 on February 26, 198 The brief description for the job covered by this wonk request is "CBS Pipe Support to RX Bldg. Spray System." The work request was ceded Quality Class I (safety-related).
ADOCK 05000312 PDC 4(
 
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The NRC inspector requested SMUD to provide objective evidence that these non-safety fasteners were in fact not used for a safety-related application. Following an investigation, SMUD presented documents ECN R-0780, dated January 9,1987, and Scaffold Request 87-657, dated January 28, 1937.- Following a review of these documents, the NRC inspector agreed with SMUD's conclusion that the fasteners were used to construct the scaffolding needed to accomplish the containment pipe support wor In general, SMUD's past practice of issuing non-safety material for use in Class I (safety-related) jobs is a concern. Other than a possible inspection of material by the QC inspector at the job site, no past procedure control was evident to explain how SMUD prevented the use of non-safety items in actual safety-related applications without some form of technical review. The SMUD Material Control Manager noted that the requirements in current Procedure RSAP-0701, Revision 0, now prohibit non-Class I material from being issued for a job with a Quality Class I code. This procedure has been in effect since June 1, 198 . Follow-up on Previously Discovered, Comingled Safety-Related and Non-Safety Fasteners During the October 1987 NRC Augumented Systems Review and Test Program Followup Inspection (50-312/87-29), the NRC inspection team discovered non-safety (Class II) cap screws (SCN 8928)
comingled in a drawer identified for safety-related (Class I) ,
cap screws (SCN 103118). According to the Material Control ,
Manager, all non-safety cap screws were subsequently removed '
from the SCN 103118 drawer. Information in the NUCLEIS data base and information on the stock record card indicates SCN 8928 is a 3/4" - 10 x 1 1/2" 304 stainless steel (grade 18-8)
cap screw that was comercially procured. The NRC inspector was concerned over the possibility that SCN 8928 cap screws may have been inadvertently issued as SCN 103118 for a safety-related application before the comingling discovery. SMUD agreed to review its previous attempt to reconcile the issued quantities of the affected SCN fasteners. However, the limited inspection
 
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time did not pennit SMUD to complete this review and provide !
supporting documentation before the inspection was over. The l NRC inspector identified two technical concerns related to this l matter. First, the two SCNs were procured according to l different material specifications: SCN 8928 is a commercially !
procured 304 stainless steel (Grade 18-8) cap screw and SCN i 103118 is an ASTM F593-85 304 stainless steel cap scre Secondly, the two SCN's are for different length cap screws; SCN 8928 is a 1 1/2" long cap screw while SCN 103118 is a 1 3/4" long cap screw. Inadvertent use of SCN 8928 for SCN 103118 could unexpectedly result in 1/4" less thread engagement length for applications requiring a 1 3/4" long fastener. SMUD !
stated they are evaluating the generic issue of comingling as l part of the response to IE Bulletin 87-0 . SMUD Actions To Improve Material Contro l l
The NRC inspection in October 1987 1dentified commingling of a l safety-related fastener (SCN 103118) with a non-safety fastener !
  (SCN 8928) as mentioned in item 4. As a result of this inspection, !
as well as other inspection and audit findings, SMUD has estab- l lished a policy that safety-related material will be located in I a cesignated safety-related material section of each warehous Non-safety material will not be located in the safety-related section. This policy is intended to provide additional assurance that safety and non-safety material will not be inadvertently commingled. Safety-related fasteners are covered by this polic Among other things, this policy will eliminate the situation found during previous inspections where safety-related and non-safety fasteners were stored in the same drawer, separated by divider During discussions with the NRC inspector, the Material Control Manager outlined additional actions taken by SMUD to improve
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material control:
  (a) SMUD recently completed a 100 percent inventory of its warehouse stock to identify deficiencies in material identification and storag !
l (b) SMUD is starting to place dated stickers on material being placed into stock. These stickers will be used to facilitate a first-in/first-out issue policy for the '
material handler . Warehouse Inspection The NRC inspectors conducted an inspection of the SMUD Rancho Seco warehouse facilities. These facilities consist of three warehouses (A, B, and GRS) located within the protected area of the site and the receipt inspection building located outside the protected are Generally, n.ost fasteners were found in Warehouse A and the GRS wdrehous Most safety-related fasteners were found in Warehouse A
 
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in the section being designated for safety-related items. Some exceptions are that safety-related fasteners such as Hilti Bolts (Class I, Procurement Level II) and threaded rods (Class I, Procurement Level II) are stored in the GRS warehouse. The GRS warehouse also contains a number of fastener stock codes identified with yellow "D0 NOT ISSUE" tags. These stock codes have been placed in a hold status pending completion of the stock material reverification progra The NRC inspectiun team toured Warehouse A to observe.how safety-related materials, components, and equipment were being controlle This included controlled access, receipt inspection, environmental conditions, marking and segregation of fasteners, control of nonconforming items, issuance of items, and housekeepin The following observations and concerns were noted by the inspection team, regarding the Warehouse A environment: (a) the potential exists for airborne contamination from the Machine Shop .ocated in the same building; (b) the overhead heaters have to be manually operated to maintain temperature control; (c) temperature requirements of 40 to 140 degrees Fahrenheit may be extreme; (d) stored items have no protection from humi11ty. The licensee had previously identified the same concerns and was in the process, during this inspection, of preparing a draft Engineering Assistance Request addressing these item During the course of the inspection, the inspection team held numerous conversaticns with Material Control personnel regarding warehousing activities. One concern identified ouring these discussions was that there appeared to be a lack of a definite understanding or set of instructions describing what actions are taken when an item is dropped or damaged. The emphasis for these instructions should be on actions to be taken by warehouse personnel during the perfonnance of their daily routine activitie For example, should an item composed of sensitive electronic components be dropped and no external damages  4 noted, should this item be placed back on the shelf or should the  I item be evaluated for possible internal damage? The licensee  l committed to revise their procedures to address this concern about  i lack of instructions for warehouse personnel. Also, on a related  !
subject, the inspection team questioned the guidance given by QAP-17,  '
"Nonconforming Material Control." This procedure states that if an item is dropped and damaged, the green accept tag shall be removed (by QC), and an NCR initiated if the item is to be issued for us Removal of the green tag prevents the nonconforming item from being issued; however, disposition of the damaged item is not addressed if the item is not intended for immediate plant use. Also,QAP-17 states that "All deficiencies have to be documented, either on a WR, NCR, ODR, or CAR." However, it was i.?t cler to the inspection team how warehouse deficiencies are documented. The licensee connitted to clarify the handling of dropped or damaged material, during the exit  l meetin . _ , _ _ _ _ , _,,. . , , - - - - --
 
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, i , The warehouse inspection was concentrated on Warehouse A and its section designated for storage of safety-related items. About 100 stock codes were randomly selected and visually inspecte These included the following: Inspection of SCN 109034 (Storage Location 04A08A07) and SCN 102958 (storage location 04A08A08).
 
An opened box of nuts for SCN 109034 was found with a green tag affixed to the box identifying the nuts as 1" - 8 SA,563GR- The heat code section on the green tag was blank. The nuts were stamped with heat code identification EXD. An opened box of nuts for SCN 102958 was found with a green tag affixed to the box identifying the nuts as 1" - 8 SA194GR-2H. The heat code section on the green tag was blank. The nuts were stamped with heat code identification EWJ. Both boxes were similar in appearance, and the nuts were the same size and similar in appearance (except for heat code markings). However, the nuts were made of different material The boxes were on the same shelf in adjacent storage positions, which presented an opportunity for unintentional commingling because opened or unsealed packages or containers do not provide positive identification control of the content If commingling had occurred, different heat code markings on the nuts would not be easy to notice and they would not necessarily alert personnel that two different types of nuts were being issue The issue proce::s requires the heat code to be documented, but not verified at issu However, the presence of heat code markings _in the nuts would have provided ultimate traceability since SMUD procedures require heat codes to be documented in a heat code log. As an additional item, these nuts should have been individually green tagged according to the requirements in SMUD procedure RSAP-0808, i paragraph 5.4.2., dated December 11, 1987. Anong other things, l this procedure requires nuts 1 inch and larger to be independently '
identified with a green ta j The findings noted above were brought to the attention of the Sturekeeper and the Material Control Manager. The Storekeeper took irrmediate action to separate the two similar looking boxes of nuts. Shortly thereafter, the Material Control Manager initiated a change to RSAP-0701 (per Material Control Manager memorandum of January 13,1988) to ensure that sealed or closed storage containers are resealed or closed following issue of bulk stored items under the control of a single green ta . Inspection of SCN 112126 (Storage Location 04A04L01)  I
 
A box of cap screws labeled with a green tag (computer generated) affixed to the box identifying the contents as safety-related (Class i Procurement Level IV) 1/4" x 1 1/2" cap screws were procured on purchase order RQ-87-081435 This sane


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, . , box also contained an unmarked package of cap screws. At the  4 request of the NRC inspector, the cap screws in the package were measured and found to be 1/4" x 1 1/4" cap screws. Except for length, the physical appearance of both sizes of 1/4 inch cap l screws was the sam l This finding is a concern because identification had been lost for the package of 1 1/4 inch cap screws, resulting in a comming- i ling of an unidentified stock code with a safety-related stock  I cod ,  i 3. Inspection of SCN 104634 (Storage Location 04A04H01)
enforcement discretion in this case and refrain from taking enforcement j action. I expect that in the future any similar problems will be promptly I identified and corrected.
i The following material was found in the drawer for this SCN:  l (o) four packages - each package contained one dowel pin, and l
each package was marked with a green tag (new computer generated), l which incicated the dowel pin was safety-related (Class I,  !
Procurement Level IV); (b) one package containing two dowel  l pins - the package was not marked; (c) one package containing six dowel pins - the package was marked with a green tag with  l no procurement level (old and hand written), indicating that  !
the dowel pins were safety-related (Class I); and (d) one loose  '
white tag - Part Number 105-002 and Purchase Order RQ-87-02-50171 were cited on this ta This finding is a concern since identification had been lost for the unmarked package of dowel pin The inspection team noted that the SMUD reverification policy in effect at the time of the inspection would have allowed the dowel pins in the package  l marked Class I to be issued for a safety-related application without any additional review or restrictio l l
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In accordance with 10 CFR 2.790(a), a copy of this letter will be placed in the NRC Public Document Roo
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Sincerely, onp d 52)"d J. B. Martin    i Regional Administrator DISTRIBUTION:
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PDR LPDR HThompson, DEDS JLieberman, OE HWong, OE LChandler, OGC EA File Day File DCS cc:
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J. Vinquist, Quality Assurance Manager    i Steve L. Crunk, Manager, Nuclear Licensing State of CA bcc:
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Docket File Project Inspector Resident Inspector G. Cook      ,
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B. Faulkenberry J. Martin A. Johnson R. Nease, NRR M. Smith LFMB     -
. . . APPENDIX A INSPECTION CHRONOLOGY AND RESOLUTION OF RESTART ISSUES l
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A procurement and material control inspection conducted by the Headquarters '
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Vendor inspection Branch (VlB) at Rancho Seco on January 4 through 14, 1988, found several deficiencies in the Sacramento Municipal Utility District's ,
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(SMUD's) procurement program and the dedication process for commercial grade I items useo in safety-related application During the exit meeting on [[Exit meeting date::January 14, 1988]], certain findings were categorized as restart issues to be addressed by SMUD before the restart of Rancho Sec On February 3,1988, in a letter from G. Carl Andognini to Frank J. Miraglia, Jr., Associate Director for Projects, SMUD submitted a "Procurement Engineering Assessment Plan" (PEAP) to address both specific and generic actions relating to restart and long-range issues. The restart concerns related to five key issues:
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* Commercial grade item dedication - connercial grade spare and replacement parts were purchased and accepted on the basis of a "like-for-like" comparison of part number onl * Piece part replacements in environmentally qualified (EQ) components -
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a potential for invalidating qualification exist I
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Seismic qualification of replacement relays in the reactor protection system (RPS) and safety features actuation system (SFAS) - a potential for invalidating qualification exist * Acceptability of Class I warehouse stock (green tag program) - the resolution of concerns were attributed to deficient procedures and practice I l
* Enhancements of existing procurement and dedication procedures and I processe Subsequent to receipt and review of the SMUD PEAP the VIB performed an !
in-process review of the SMUD engineering evaluation of installed connercial I grade items for EQ and seismically qualified components during February 10 ;
through 12, 1988. The inspectors found that the. methodology employed by SMUD to perform the engineering evaluation was adequat The inspectors reviewed 10 evaluations completed in accurdance with the enhanced l
procedures for items that required dedication to ensure that the installed '
connercial crade items would perform their intended safety function. Questions concerninE 4 of the 10 items were raised by the inspectors and were left unresolved /open at the exit meeting on [[Exit meeting date::February 12, 1988]]. Several conference calls between SMUD and the NRC VIB took place between February 18 and March 1 to resolve the inspectors' questions. SMUD committed to address the outstanding l procurement and material management concerns in an interim repor '. .
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The PEAP Interim Report was received by the NRC on March 1, 1988, and provided the results of the technical engineering evaluations performed on a sample of selected components and parts installed or available for installation in Class 1 system SMUD stated that the evaluations were conducted in accordance ,
with detailed instructions and ensured that parts procured as comercial grade i items did not adversely affect the safety function of the components or system l This evaluation methodology was used to address the seismic quaiification of relays in the SFAS and the RPS and the environmental qualification for piece I part replacements. Class 1 warehouse stock was evaluated by judging the 4 adequacy of a sample of items with green tags currently available for safety-related application i The NRC review of the PEAP interim report found that most evaluation areas ;
still had work to be completed and raised questions concerning the dispositions of the nonconfonnance reports (NCR's) identified by SMUD during the EQ evalua-tion, the green tag program review, and the original commercial grade item evaluations from the January inspectio The VIB conducted an inspection from March 7 through 9,1988, to follow up questions and concerns identified in the PEAP interim report review, as well i as those identified in the previous inspections. This inspection addressed 1 specific hardware issues ano included a generic review of the EQ piece parts evaluation, dedication of the seismically qualified SFAS and RPS relays and the acceptability of warehouse stock with Class 1 noncommercial grade green tags. The issues involving specific hardware concerned EQ accelerometers located in the acoustic monitors for the main steam system atmospheric dump valves, the EQ wiring in the hydrogen monitor heater cabinets, a GE relay in the sampling system, an ASCO coil in the hydrogen monitor solenoid, and an Agastat relay in the undervoltage protection system. Resolution of the deficiencies of the wiring, the ASCO coil and the Agastat relay required replacement of these items with qualified and dedicated equipment. The deficiencies that caused equipment replacement were evaluated and attributed to weaknesses in the procurement process or, as in the case of the hydrogen i monitor wiring, the licensee's deviating from the work authorization. The !
licensee review of records and inspection of similar equipment determined that these deficiencies were isolated and did not affect similar items installed in the plant. The licensee accepted the accelerometers and the GE relay on the basis of satisfactory resolution of the identified concerns. Many other specific component concerns were addressed in the interim report and dispositioned by SMUD as acceptable for service based upon subsequent successful dedicatio The environmental qualification piece part evaluation was applied to all EQ replacement ports procured as comercial grade and installed since November 30, 1985. The review identified 484 EQ components representing 11 different equip- ;
ment categories. Approximately 740 work requests were identified that involved l part replacement or modification. SUMD committed to review 25 percent of '
these work requests before restart. At the time of the inspection, the licensee reviewed end approved 186 work request These work requests translated into 252 EQ parts, of which 9 were procured as Quality Class 1, leaving 153 comercial grade replacements parts. These 153 parts required 20 l     l
 
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l commercial grade item dedications in accordance with SMUD Instruction l No. ERT-05, "Engineering Evaluation of Previously Installed Comercial Grade Items In Safety-Related Systems." These 20 dedications represented the vast najority of the 153 parts because of duplication of parts. With the exception of one outstanding certification from ASCO for a solenoid valve SMUD was able .
to dedicate all of the replacement ports to today's standards through the l various methods described in Instruction ERT-0 '
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l To assess the acceptability of comercial grade replacement relays in the RPS I and the SFAS, the licensee reviewed all relays the licensee reviewed all relays in these systems to identify those that have been modified or replaced since l system installation. The work request review identified a total of 1114 i relays in these systems, but only 21 relays / modules have been replaced by l either new or replacement parts. The licensee evaluated the 17 relays that I were procured comercial grace and found that they could be properly dedicated ,
for use in a Class 1 seismic application. The 17 relays were dedicated to the l requirements of ERT-05 upon receipt of Certification of Compliances (C of Cs) I from the original vendors. The inspectors reviewed the evaluations of the 17 comercial grade relays ano cetermined that the dedications to the require-ments of ERT-05 were adequat To provide assurance that Class 1 items (currently available in the warehouse for installation in Class 1 systems) have the required procurement and inspection documentation, SMUD comitted to review 6pproximately 75 items in the warehouse that were procured before implementation of the current procure- i ment program (1987) and that are green tagged as Class 1 and are available for issue. The January 1988 VIB review of the green tag reverification program found that SMUD had not obtained objective evidence to support the placement of the equipment vendors on SMUD's approved suppliers list (ASL). This fact is important since SMUD had previously placed vendors on its ASL solely on the basis of a desk audit of the vendor's QA program. At the exit meeting on March 9,1988, SMUD committed to obtain evidence indicating that the green-tag material suppliers' QA program implementation had been verified during the approximate time period of the purchase of the 75 items reviewed. Any stock code item not reverified by restart will be placed on hold in the warehous The green tag review showed that three NCRs were identified as well as 11 l instances in which the requirements of 10 CFR Part 21 were not imposed on the <
Class 1 vendor. For two of the three NCR's, SMUD was able to obtain informa-tion to qualify the items. The third NCR involved ASME fittings obtained from a vendor (Ladish) who did not hold an ASME certificate during the time of manu-facture, and SMUD could not demonstrate with existing documentation that Ladish was authorized to distribute material certified to Section III of the ASME Code, nor had they audited the Ladish quality program. However, SMUD showed that Bechtel hed performed surveys and audits of Ladish for the period in questio SMUD stated that because the material could be traced tu the original supplier and the audits performed by Bechtel on the Ladish plant were satisfactory, reasonable assurance was provided that the material, as received onsite and installed in the plant, was acceptable for use in Class 1 systems. SMUD also stated that the only systems required to meet ASME Section III requirements
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    -4-were those associated with the emergency diesel generator. SMUD verified that none of these parts was installed in these systems; however, they had been available for ASME applications. SMUD committed to take corrective action to prevent the use of these parts in ASME systems in the futur In summarizing the total SMUD effort as part of the PEAP restart review for Class 1 applications, a total of eight NCRs were identified in the vjrioys review area Three parts had to be removed from service and replaced with either properly dedicated or Class 1 parts. The NCRs were satisfactorily dispositioned for the remaining parts. Many other parts required various evaluations and additional documentation in order to be considered adequately dedicated. The goal of PEAP was to determine if the parts installed or the parts available for installation in Class 1 safety-related applications would be able to perform their safety functions when required. It appears, based upon review of all of the areas before the restart of Rancho Seco, that adequate assurance exists, even with less than adequate past practices in the areas of procurenant, material control, and evaluation of vendors, that it is unlikely that the reliability of safety-related equipment has been significantly compremised. Long-term corrective actions are continuing with commitments to complete the EQ piece part review by Juae 30, 1988, and the warehouse stock reverification by September 30, 198 ,
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APPENDIX B
. . . PERSONS CONTACTED Sacramento Municipal Utility District
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*B. G. Croley, AGM, Technical and Admin. Services
*J. V. Vinguist, Director, Nuclear Quality  ,  l
*J. F. Firlit, AGM, Nuclear Power Production  , l
*G. V. Cranston, Manager, Nuclear. Engineering Department (NED) ,. i
*S. L. Crunk, Manager, Nuclear Licensing
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*J. T. Telford, NED, Project Manager    '
*G. J. Legner, Licensing
*T. E. Redican, Manager, Material Control  i
*R. A. Savoie, NED    '
*S. Woca, NED
*J. M. Meyer, QA Manager
*R. Wise, NED - Impell
*P. DiDonoto, NED - Tenera
*R. Desautels, NED - Tenera
*B. Kumar, NED
*S. Sarver, Licensing    l
*T. F. Fetterman, NED    '
M. Lawrence, NED    l R. Chackal, NED - Impell S. McCloskey, NED - Tenera L. Lew, NED - Bechtel T. Maxey, NED - Tenerd R. Deguchi, NED M. Delgado, Material Control C. Wandell, NED - Impell M. Kermani, NED F. Sheehun, NED J. Walkin, NED P. Patel, NED W. Weaver, NED J. Kelly, hED
*R. J. Overlash, Duke Power    .
F. Lopez, Storekeeper, Material Control  {
J. Westvold, QA    !
huclear Regulatory Comission
*J. B. Martin, Regional Administrator, RV  1 t
*J. L. Crews, RV
*L. Miller, RV
*A. D. Johnson, RV
*J. G. Partlow, Director, Division of Reactor Inspection and Safeguards, NRR
* Potapovs, NRR
* D'Angelo. Senior Resident Inspector
* Meyers, Resident Inspector
* Kalman, Project Manager, hRR
* Attended exit meetin l
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Latest revision as of 06:36, 16 December 2021

Discusses Insp Rept 50-312/88-02 on 880104-14,0210-12 & 0307-09.Violations Noted.Advises That Violations Demonstrated Lack of Mgt Control Over Certain Aspects of Procurement Program.Enforcement Action Not Necessary
ML20246P038
Person / Time
Site: Rancho Seco
Issue date: 05/12/1989
From: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Firlit J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
EA-89-058, EA-89-58, NUDOCS 8905220065
Download: ML20246P038 (2)
v • d • e


Text

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. ;pa m g'o UNITED STATES 8 p, NUCLEAR REGULATORY COMMISSION s i, ej REGION V g 1450 MARIA LANE, SulTE 210

%'+, + n * * * 4 0 WALNUT CREEK, CALIFORNIA 946964368 M AY 1 2 1989 Docket NO. 50-312 License No. DPR-54 EA 89-58 i

Sacramento Municipal Utility District l

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ATTN: Mr. Joseph F. Firlit Chief Executive Officer, Nuclear 14440 Twin Cities Road Herald, California 95638-9799 Gentlemen:

SUBJECT: NRC INSPECTION REPORT NO. 50-312/88-02 This refers to the NRC inspection conducted on January 4-14, February 10-12, and March 7-9, 1988 at the Rancho Seco Nuclear Generating Station. By letter dated August 18, 1988, the above referenced inspection report was sent to yo As described in the report, it was discovered during the inspection that certain of your past activities related to procurement and material control apparently had been conducted in violation of NRC requirements. After the inspection, but befoce we authorized you to restart the reactor in March 1988, we verified that you had initiated comprehensive corrective action In addition, since restart of the reactor, we have been substantially setisfied with the implementation of your program for procurement and material contro The violations identified during the NRC inspection involved: (1) failure to properly dedicate several commercial grade items used in safety-related ,

applications; (2) failure to adequately evaluate vender quality assurance '

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requirements before placing some vendors on the approved supplier list; and (3) failure to impose Part 21 requirements on certain vendor These violations demonstrated a lack of management control over certain aspects of your procure-ment progra l The NRC considered these violations a significant regulatory concern, and in the aggregate they represented a Severity Level III proble Normally, a civil penalty is considered for a Severity Level III violation or problem. However, in this case, a Notice of Violation or civil penalty will not be proposed because: (1) a program of identifying and correcting problems was implemented while the plant was in an extended shutdown related to prior poor performance; (2) NRC concurrence was needed prior to restart from that outage; (3) the the violations for the most part involved procurement activities performed under procedures and policies in effect prior to the shutdown; and (4) your corrective actions were responsive to the violations, and subsequent NRC have shown the corrective actions to be effective. In sum, enforcement action is not necessary to achieve appropriate remedial action. Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13, 1988),Section V.G.2, and after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support, I have been authorized to exercise l

1 0 8905220065 890512 P~

PDR Q

ADOCK 05000312 PDC 4(

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MAY 121983

. Rhn'cho Seco Nuclear Generating Station -2-i

enforcement discretion in this case and refrain from taking enforcement j action. I expect that in the future any similar problems will be promptly I identified and corrected.

In accordance with 10 CFR 2.790(a), a copy of this letter will be placed in the NRC Public Document Roo

Sincerely, onp d 52)"d J. B. Martin i Regional Administrator DISTRIBUTION:

PDR LPDR HThompson, DEDS JLieberman, OE HWong, OE LChandler, OGC EA File Day File DCS cc:

J. Vinquist, Quality Assurance Manager i Steve L. Crunk, Manager, Nuclear Licensing State of CA bcc:

Docket File Project Inspector Resident Inspector G. Cook ,

B. Faulkenberry J. Martin A. Johnson R. Nease, NRR M. Smith LFMB -

n /6/I73-p]., ,,+ ) ~{' '

, p , ( V ' y 4 gj.tl ' , ,,gf, ,,

jn fr* f fi ) Sy^'"^

OE OE:D DEDS RV e A,A

'g .s

/ / r), [

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HWong JLieberman HThompson MBlume I _

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