ML20133G751

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)

See also: IR 05000382/1985004

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

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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 applications. The inspection involved

42 inspector-hours onsite by one NRC inspector.

Results: Within the area inspected (Procurement), two violations were ident-

ified in paragraph 2. 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 qualification.

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DETAILS

1. 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, 1985.

The NRC inspector also interviewed other licensee and contractor

personnel.

2. Review of Licensee Significant Deficiency

(0 pen) SCD-63 Procurement of Spare and Replacement Parts

a. LP&L Operation Phase Spare, Repair, and Replacement Parts for the

Emergency Feed Water (EFW) Pump Motors.

(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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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 verified.

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 requirements.

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-63.

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 finding.

(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 parts.

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

finding.

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

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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 2.f

for the disposition of this finding.

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 10.

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 requirements.

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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(a) September 23, 1976, an EBASCO letter accepted the proposed

i Industrial Engineering and Equipment Co. (INDEECO) QA

program corrective action.

(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 EBASCO.

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 assessed.

Safety-related components supplied by INDEECO are seismic

Category 1.

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 program.

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).

c. 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 environment.

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 2.b

above). The LP&L engineer stated that he had not. '

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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 2.f

for disposition of this finding.

d. 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, respectively.

Both of these EBASCO orders had relatively recent changes, as did the

applicable EBASCO design specifications. The changes post-dated

delivery of the components.

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 order.

For P0 NY 403431, the NRC inspector could find no documentation that

10 CFR 21 was invoked on the vendor.

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

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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

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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 parts.

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 applications.

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

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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

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procedure or documentation that this factor was considered by either

LP&L or B&R during their review of SCD-63.

I LP&L personnel identified procedure PE-2-014 as being the applicable

. procedure governing EQ replacement parts and components during the

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

. gave him a copy of the current procedure.  ;

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, 1984.

. (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 furnished.

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! 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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(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 documents.

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

! methods.

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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 methods.

(5) Section 5.10 references the presently nonexistent procurement

task force coordinator.

(6) Section 5.10.1 requires generation of records showing proper

j storage and maintenance during storage of EQ material, review of

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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 EQC.

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)).

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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 2.

4. 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 inspection.

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