IR 05000382/1985004

Insp Rept 50-382/85-04 on 850211-15.Violation Noted:Failure to Have Procedures for Verification of Supplier Acceptance of Design & Quality Changes & Review of Spare Parts Against Ebasco as-built Specs

ML20133G751
Person / Time
Site:	Waterford
Issue date:	10/03/1985
From:	Boardman J, Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133G722	List: ML20133G719 ML20133G724 ML20133G751
References
50-382-85-04, 50-382-85-4, NUDOCS 8510160109
Download: ML20133G751 (9)

Text

APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/85-04 Operating License: NPF-26 Docket: 50-382 Licensee: Louisiana Power and Light Company (LP&L)

142 Delaronde Street hew Orleans, Louisiana 70174 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Taft, Louisiana Inspection Conducted: Februa ry 11-15, 1985 Inspector: .

J h. Boardman, Reactor Inspector, Operations if27k Dat6

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' ections, Reactor Safety Branch

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Approved- D$M i /c/r W G. L. Constable, Chief, Project Section C Dat6 '

Reactor Projects Branch Inspection Summary Inspection Conducted February 11-15, 1985 (Report 50-382/85-04)

Areas Inspected: Reactive, unannounced inspection of followup on previously identified licensee procurement items, including replacement components and parts for safety-related application The inspection involved 42 inspector-hours onsite by one NRC inspector.

Results: Within the area inspected (Procurement), two violations were ident-ified in paragraph Failure of documentation of replacement parts for safety-related ventilation heaters for charcoal filters to meet quality and design certification requirements, and failure to have procedures: (1) for verification of supplier acceptance of design and quality changes, (2) review of spare parts against EBASCO as-built specifications, (3) design change review of purchase order major exceptions, (4) and maintenance of equipment qualificatio PDR %$$ p O

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-2-DETAILS Persons Contacted Principal Licensee Employees K. Simister, Commercial Manager R. P. Barkhurst, Plant Manager

• T. F. Gerrets, Corporate Quality Assurance (QA) Manager

• J. Woods, Plant QA Manager

• T. Chiles, Material Superintendent

• K. Brewster, On-Site Licensing Engineer G. Wuller, On-Site Licensing G. Ingrahan

• P. V. Prasankumar, Technical Support Supervisor

• W. M. Morgan, Vendor QA Manager F. J. Englebracht, Manager Plant Administrative Services M. Hamilton, Plant Engineering

• A. S. Lockhart, Consultant

• S. Alleman, Assistant Plant Manager Technical Services J. J. Zabritski, Plant Quality R. Naylor, Project Engineering

• J. B. Perez, QA Support Supervisor (OPS)

NRC Personnel

• G. L. Constable, Senior Resident Inspector

• T. Flippo. Resident Inspector

• Denotes those attending the exit interview on February 15, 198 The NRC inspector also interviewed other licensee and contractor personne . Review of Licensee Significant Deficiency (0 pen) SCD-63 Procurement of Spare and Replacement Parts LP&L Operation Phase Spare, Repair, and Replacement Parts for the Emergency Feed Water (EFW) Pump Motor (1) (Closed) Unresolved Item (8501-02) - Lack of licensee procedure to verify supplier acceptance of and compliance with purchase i order changes for safety-related parts, components or material which affect quality (Unresolved).

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-3-During this inspection the NRC inspector determined that the licensee had no procedures to verify supplier acceptance of, and compliance with, purchase order changes not substantiated by Certified Material Test Reports (CMTRs) and other such cases where specific required data can be verifie This fact was determined by review of licensee purchase order (P0) L222580. As discussed in NRC Inspection Report 50-382/8501, Bingham-Williamette personnel said that they had no documentation of receipt of Supplement 3 to the subject order. Licensee procedures do not require verification and documentation of vendor acceptance of P0 changes, nor does the licensee require certificates of conformance, or compliance to identify the revision of the purchase order, when P0 changes modify safety-related design or quality requirement Procedures and documentation available to the NRC inspector show that the P0 revision to which the parts were applied was not verified by either the licensee or Burns and Roe (B&R) during review of SCD-6 Licensee personnel indicated that they would revise existing procedures to incorporate these controls for future procurement but not for previously procurred parts. See paragraph 2.f for the disposition of this findin (2) Lack of Design Review for LP&L Major Exception Forms By Major Exception form dated November 28, 1983, LP&L made all items on P0 No. L22258D " commercial grade," including the motor core (stator) which was covered by equipment qualification (EQ)

to NUREG 0588. This major exception was not reviewed or signed by the LP&L EQ coordinator, nor did it have a design review, including a 10 CFR 50.59 review, by either plant eng).ieering or LP&L project engineering. This Major Exception form was processed after the completion of the B&R review of spare part LP&L project engineering told the NRC inspector that the motor core could not be accepted unless an acceptable analysis could be performed on its insulation system for compliance with its EQ requirements. The motor core had not been accepted, but it could have been accepted based on LP&L procedures and the requirement of the purchase order'at the time this item was identified by the NRC inspector. See paragraph 2.f for disposition of this findin At the time of this inspection LP&L procedures did not require'

review of Major Exception forms for design changes, including the deletion of EQ requirements and performance of a review in i

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-4-accordance with 10 CFR 50.59, as necessary to meet the require-ments of 10 CFR 50, Appendix B, Criterion III. Criterion III states that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organiza-tion that performed the original design unless the applicant designates another responsible organization. See paragragh for the disposition of this findin b. Procurement of Phase Safety-Related Components and Parts for Ventilation Systems Filter Heaters (1) Deletion of Original Design Requirements for Replacement Parts LP&L PR 51313, P0 L260980, specified safety-related parts to the requirements of the original equipment ordered by EBASCO on P0 No. NY 403553, Supplements 0-8, and EBASCO specification LOU 1564.748D, Revision 1 LP&L Major Exception form dated September 27, 1982, removed the original EBASCO requirements for these components and parts and made them nonsafety-related, no QA required. (It also deleted P0 items 16-22.) This deletion of EBASCO requirements was not approved by LP&L plant engineering or LP&L project engineering, or another organization authorized to review design changes, as

! discussed in paragraph 2.a(2).

(2) Original EBASCO Safety-Related Ventilation Heating System did not meet Certification and Quality Assurance Requirements

The reason for the Major Exception form, dated September 27,

.i 1982, was a letter from the safety-related ventilation heater system manufacturer stating that the LP&L P0, which duplicated the requirements of the original EBASCO P0, " required certification and quality assurance program requirements which are considerably beyond those under which the original electric heating coils were manufactured. If it is mandatory that these requirements be met as stated in the requests, we will be unable to offer a quotation of these replacement parts." This letter categorically stated that INDEECO could not, and had not met the EBASCO requirement The NRC inspector reviewed available site documentation to determine EBASCO QA approval of this manufacturer. EBASCO documentation identified to the NRC inspector on site during the inspection and by telephone from LP&L on February 25, 1985, shows only the following:

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-5-(a) September 23, 1976, an EBASCO letter accepted the proposed i Industrial Engineering and Equipment Co. (INDEECO) QA program corrective actio (b) August 1978 disapproval by EBASCO of INDEECO's QA Manual .

(c) September 1978 disapproval of INDEEC0's revised QA Manual by EBASCO.

(d) October 1982 approval of INDEECO by EBASC A review of material receipts for INDEECO on P0 No. NY 403556 shows most material apparently was received between 1977 and 1979 with two receipts in December 1982. As a result, essentially all actions performed by INDEECO were performed using a QA program which had not been approved by EBASCO. Al so ,

as stated in the beginning of paragraph 2.b.(2), INDEEC0 documented that they never met involved requirements.

1 10 CFR 50, Appendix B, Criterion VII requires control of purchased material and that the effectiveness of the control of quality by contractors be periodically assesse Safety-related components supplied by INDEECO are seismic Category Waterford 3 Steam Electric Station FSAR, Table 3.2-1, Note 13, 1 states that all structures, systems and components identified as

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seismic Category 1 receive the full 10 CFR 50, Appendix B l quality assurance progra Documentation does not support that LP&L met 10 CFR 50, Appendix B, Criterion VII, with regard to assurance of the acceptability of INDEEC0's compliance with Waterford 3 design base procurement requirements for safety-related ventilation ,

heaters and associated components, and replacement parts, used with charcoal filters. This failure is an apparent violation of 10 CFR 50, Appendix B, Criterion VII (50-382/8504-01). LP&L Accertance of Spare and Repair Parts Without Design Control On Spare Parts Equivalency Evaluation Report (SPEER)85-159, dated February 11, 1985, LP&L plant engineering performed a technical  :

review of a shield butiding ventilation EHC power switch ordered as ,

ncnsafety-related, commercial grade on LP&L P0 L260980. This switch was classified on the SPEER as Class 1E, seismic, harsh environmen The component was accepted. The NRC inspector asked the plant

! engineer who prepared the SPEER if his review included verification

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that the switch met the requirements of the latest revisions of the EBASCO specification and the original EBASCO P0 (see paragraph above). The LP&L engineer stated that he had no '

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- 6-The NRC inspector had determined that Revision 12, dated August 17, 1984, was the latest revision of EBASCO specification 1564.7480, and that Supplement 12 dated November 15, 1984, was the latest to EBASCO P0 NY 403558. The NRC inspector could find no procedure to require, or document, that previously purchased operation phase spare components and parts be reviewed prior to use for design control relative to changes in EBASCO specifications, to assure that replacements for safety-related applications meet the latest design requirements. Such a lack of procedures was covered in NRC Inspection Report 50-382/84-42, violation (8442-01) but this specific exan.ple was not in the licensee response to the violation. See paragraph for disposition of this findin Recent EBASCO Changes to Purchase Orders for Which all Material had been Delivered and Apparent Failure to Invoke 10 CFR 21 on Suppliers In conjunction with review of LP&L P0 L-26098-D and L-22258-D, discussed in Sections 2a, 2b, and 2d above, the NRC inspector reviewed the original EBASCO purchase P0s for the involved material, NY 403556 and NY 403431, respectivel Both of these EBASCO orders had relatively recent changes, as did the applicable EBASCO design specifications. The changes post-dated delivery of the component As reviewed in the LP&L project records files, EBASCO P0 HY 403431 contained Supplement 14, issued December 9, 1983, and EBASCO specification LOU 1564.177R3, dated December 7,1983. There was no documentation in the LP&L project records that the vendor had accepted this, or any supplement of the EBASCO order. LP&L project records were missing Supplements 10 through 12 of the EBASCO orde For P0 NY 403431, the NRC inspector could find no documentation that 10 CFR 21 was invoked on the vendo As reviewed in the LP&L project records files, EBASCO P0 NY 403556 contained Supplement 12 dated November 5,1984, and specification

! LOU 1564.7480, Revision 12, dated August 17, 1984 No documentation

] in LP&L project records showed acceptance by the vendor of any PO 4 Supplement, and Supplements 4 through 8 were not in LPAL project

records.

{ The issuance of P0 supplements transmitting revised design speciff-

! cations after material delivery, the lack of completeness of LP&L

project records files, and the apparent failure to invoke 10 CFR 21 i

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on manufacturers, such as the manufacturer of the seismic Category 1 safety-related system for charcoal filter heaters (see paragraph 2.b(2)

for the apparent deficiencies of this vendor) will remain an unresolved

item (50-382/8504-02) pending further review by the NRC inspector

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during a subsequent inspection.

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e. Apparent Problems Related to the LP&L Procedure Governing Procurement of Safety-Related Replacement Components and Parts Requiring

, Equipment Qualification (EQ)

As part of the evaluation of SCD-63, the NRC inspector began a review

.l of the licensee procedure for procurement of EQ replacement r components and part LP&L plant engineering identified to the NRC inspector Administrative

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Procedure PE-2-014, Equipment Qualification, Revision 1, dated January 15, 1984, as being applicable for procurement of replacement

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components and parts for EQ applications.

1 PE-2-014 Revision 0, was approved September 29, 1982. Prior to that time there was no LP&L procedure controlling EQ or the procurement of replacement components and parts for EQ application ,

From 1978, when LP&L initiated procurement of operations phase I

replacement, components and spare parts, until 1982 when PE-2-014, j Revision 0, was issued, there was no procedure or EQ coordinator to prevent the ordering, acceptance, and installation of unqualified

components and parts for EQ applications. There is no identified d

procedure or documentation that this factor was considered by either LP&L or B&R during their review of SCD-6 I LP&L personnel identified procedure PE-2-014 as being the applicable

. procedure governing EQ replacement parts and components during the i

exit interview on February 15, 1985, and after the exit interview,

. gave him a copy of the current procedur ;

Subsequently, the NRC inspector reviewed the procedure, identifying the following problems which were identified to LP&L:

1 (1) Reference 2.20.3 is LP&L procedure UNT-8-002, " Processing of Station Procurement Documents." UNT-8-002 is referenced in

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Section 5.7 but was cancelled January 28, 198 . (2) Section 3.12 states like-for-like - Description of replacement i of an item with an exact duplicate. The replacement must be by

the same manufacturer and be the same model and design.

] Section 5.4.1.1 states that, for a previous qualification to

, remain valid, design of the item and its production controls have not been changed. Section 5.4.1.3 states that adequate j documentary proof of 5.4.1.1 must be furnishe ! As discussed in this report, LP&L has ordered replacement parts

for EQ applications as commercial grade without verification or j documentation that they are the same design as the part

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originally qualified, or under the same production controls.

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-8-(3) Section 4.2.1.2, Engineering and Technical Services Group (ETS)

shall ensure that all required vendor documentation is

> furnished. This requirement interfaces with Section 4.6 which

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requires the nonexistent procurement task force coordinator (EQC) to review safety-related purchase and receiving document The LP&L materials management group, which replaced the procurement task force, was unaware of this requirement, and had not complied with it. As a result, apparently none of these sections have been complied with .

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(4) Sections 5.4.4, 5.8.1.4, 5.11.4, 5.12.2.2 and 5.12.4.1 refer to LP&L procedure UNT-8-001 for qualification requirements and

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Section 5.8.1.4 references UNT-8-001, Attachment 6.18. No approved revision of UNT-8-001 contained an Attachment 6.18, or qualifico:1on requirements and method (5) Section 5.10 references the presently nonexistent procurement task force coordinato (6) Section 5.10.1 requires generation of records showing proper j storage and maintenance during storage of EQ material, review of i

these records by the EQC and identificatien of the records as qualification records. LP&L materials management personnel were unaware of this requirement of review by the EQ Based on these findings, LP&L did not have in-place implenenting

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procedures for maintenance of equipment qualifications, including their comitment to have such procedure prior to fuel load as committed in Section A6 of Revision 2 (November 1982) of LP&L's

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Waterford SES Unit No. 3 Response to NUREG-0588 Revision 2. See i paragraph 2.f for disposition of this finding, f. Apparent Failure to Comply with 10 CFR 50, Appendix B, for Procedures Governing Replacement Components and Parts for Safety-Related Applications and Maintenance of Equipment Qualification

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10 CFR 50, Appendix B, Criterion V requires that activities affecting 1 quality shall be prescribed by documented procedures. As discussed above, LP&L failed to have procedures:

(1) To verify vendor acceptance of, and certification of compliance to, (where applicable) purchase order changes which affect the design or quality of safety-related equipment parts or material (paragraph 2a(1)).

I i (2) To require design review, including a 10 CFR 50.59 review, of P0

major exceptions (paragraphs 2.a(2). l

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(3) To assure the review of previously procured, and to procure future replacement and spare parts, components, and material to the final EBASCO "as built" specifications (paragraph 2c).

(4) To assure maintenance of Equipment Qualification as committed (paragraph 2.e)

Failure to have procedures for activities affecting quality is a violation of 10 CFR 50, Appendix B, Criterion V (50-382/8504-03).

3. Unresolved items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph . Exit Interview The NRC inspector met with the licensee representatives (denoted in paragraph 1) and the NRC resident inspectors at the conclusion of the inspection on February 15, 1985. The NRC inspector sunmarized the purpose, scope, and findings of the inspectio I t

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