ML20006E330

Forwards Fee in Amount of $25,000,in Response to 891019 Notice of Violation & Civil Penalty Re Commercial Grade Procurement,Per Insp Repts 50-282/88-201 & 50-306/88-201. Responses to Violations Also Encl

ML20006E330
Person / Time
Site:	Prairie Island
Issue date:	11/20/1989
From:	Larson C NORTHERN STATES POWER CO.
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
NUDOCS 9002220676
Download: ML20006E330 (9)

Text

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, b Northem States Power Compey l

414 Nicol 6et Mall . .

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Minneapolis, Mannesota 664011927 i Telephone (612) 330 6600 i

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November 20, 1989 i

Director, Office of Enforcema.nt . '

US Nuclear Regulatory Commission Washington, DC 20555 3

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PRAIRIE ISIAND NUCLEAR CENERATING PIANT  !

Docket Nos. 50 282 License Nos. DPR 42  ;!

50 306 DPR-60  !

4 Reply to a Notice of Violation and Civil Penalty Concerning Commercial Crade Procurement j NRC Inseection Renorts 282/88 201 & 306/88 201

Reference:

Letter from A Bert Davis, Regional Administrator, Region III to C E Larson dated October 19, 1989 titled: " Notice cf Violation and Proposed Imposition of Civil Penalty"  ;

Attached is a check in the ascunt of $25,000 payable to the Treasurer of the  ;

United States in full payment of the civil penalty imposed in- the referenced letter.

Written responses to the two violations are attached.

Please contact us if you have any questions related to our responses to these  !

v!.olation *

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C E Lars u Vice Pres ent Nuclear Generation c: Regional Administrator, Region III, NRC Senior Resident Tuspector, NRC NRR Project Manager, NRC C Charnoff

Attachment:

Responses to Violations Check for $25,000 to the Treasurer of the United States M If i

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.9002220676 891120  ;

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ATTACHMENT PRAIRIE ISLAND NUC11AR CENEPATING PIANT l Resnonses to Violations l

l Violation No. I 10-CFR 50, Appendix B, Criterion III, requires in part, that measures be established for the selection and review'for suitability of matarials, parts, equipment, and processes that are essential to the safety related functions of structures, systems and components. ,

i contrary to the above, as of October 25, 1988, the licensee failed to '

' establish adequate measures for selection and review for suitability of '

application of items purchased commercial grade that are essential to the safety related functions of systems and components. The measures were inadequate in that the licensee failed to perform documented technical ,

evaluations to identify attributes such as the components' safety functions  ;

and critical characteristics, verification of design and ,

canufacturing/ material changes, and receipt-inspection requirements beyond,  !

generally, a part number verification and check for physical damage and  ;

cleanliness. Consequently, the following commercial grade components of '

undetarained quality were installed in safety related systems.

A. Seven General Electric (GE) type THEF136050 molded case circuit breakers were' installed in safety related applications: two were used as supply '

breakers in the motor control conter cells for two feedwater.co steam generator motor operated isolation valves; four were used in station battery chargers 11, 12, 21 and 22; and one was used as the supply breaker to AC distribution panel 136 supplying power to the diesel '

cooling water pump 121.

B. Kun'kle relief valves (1/2 and 1 inch) were installed in the emergency diesel gensrator starting air system.

C. A 30. amp circuit breaker purchased from the Woutinghouse Electric company was-installed in the safety injection pump heat traco system. ,

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Composite rupture discs procured from BS&B Safety Systems / Sin.one Engineering were installed on the auxiliary feedwater pump turbine exhaust header.

E. A 4-pole positive action switch procured from Foxboro corporation was installed in the main control board as a test switch for the fuel channel T-hot input.

F. A Square D Model 9012 TP CAW 6 pressure switch purchased from the John Henry Poster Company was installed in the diesel generator No. I starting air compressor.

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< C. A 5400 microfarad capacitor procured from Solid Station Controls. Inc. .

was installed in the No. 21 safety related inverter. l H. A 2 pole,100. asp circuit breaker procured from Westinghouse Electric Supply Company was installed in the No.12 safety related inverter.

1. Foxboro Modal 62H relays were installed in the flux tilt controllers.

This is a Severity Level III violation (Suppletant 1).

Civil Penalty - $25,000 -

M g13 pion of the Allered Violation Adequate measures were not previously established to fully assure that selection and review of commercial grade items met suitability requirements for use in safety related functions. The existing measures were inadequate in i that documented technical. evaluations failed to identify ar. tributes such as l the components' safety functions and critical characteristics, verification of l design and manufacturing / material changes, and receipt inspection requirements 1 beyond, generally, a part number verification and check for physical damage ,

and cleanliness. I We have been actively working to upgrade our program for the review and i application of commercial grade items. The following discussion explains the l history of oar program: l l

In October of 1986 an EPRI/NCIG project RPQ1017 (Guidelines for )

Utilization of Commercial Grade Items in Nuclear Safety Related 1 Application) was initiated to define the scope of an engineering 1 evaluation. We participated in this effort an evidenced by inclusion of Northern States Power on the acknowledgement (page V) of the NCIC 07 final ,

report, issued June 1988. l 1

In January of 1987, we established a Procurement Ad Hoc Committee to review )

and revise the uniform procurement process, with commercial grade l

.procureraent as the top item on the list of issues requiring resolution, l Work by this NSP committee continued in parallel with the development of I the EPRI document.

The fi'est draft of N1AWI 6.1.9 Rev 1 " Commercial Grade Procurement" to  ;

incorporate EPRI requirements was presented to management on April 13, 1968. Comments continued to be incorporated and the final draft was compared to the EPRI final report in July of 1988.

In October of 1988, management directed that N1AVI 6.1.9 Rev 1 be l implemented on a trial basis in order to " evaluate the process and to build I a base of Commercial Grade Evaluations for a smooth transition to this process at full implementation". " Full implementation...... is scheduled for the first quarter, 1989." l l

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l On March 13, 1989,- NSP management committed through NUMARC to implewent n EPRI NP 5652, for all future purchases.' on March 21, 1989, NRC issued L

Generic Latter 89 02, which conditionally endorsed EFP.I NP-5652.

We will continue to upgrade our program.with improvements in inventory control and identification,- control of parts during testing, review of internal and external company testing capabilities, and participation on EPRI committees addressing purchtse'of parts and maintenance of parts inventory. The upgraded program will address the weaknesses-reported in the NRC inspection report, A quality assurance audit of the implementation of the Commercial Crade Procurement program was performed in August of 1989. The program was found to be " effective and improv!.wj".

t Reasoas for the Violation The reason for the violation was a lack of appreciation and understanding et the requirements of 10 CFR Parc 50, Appendix B for engineering evaluations for commercial grade items.-

' Corrective Stens Taken and Pesults Achieved A review of a representative selection of commercial grade parts dedicated for l: use.in safety.related service will be completed by December 31, 1989 l

(Reference 1). This sample will consist of items installed in safety-related equipment from January, 1985 through November, 1088 meeting t..a following

• criteria:

Environmentally Qualified Equipment

) Essetor Protection System l

lE Switchgear ,

L , Key Suppliers (Foxboro, Limitorque, Asco) 1

' All commercial grade ps-ts purchased after November 4,1988 will have proper

) engineering evaluations and documentation of the evaluations as stated in Reference 1.

' Item Eptaific Corrective Actions:

i, Ac CE THEF Circuit Breakers inese breakers were replaced with qualified breakers.

B. Kunkle Relicf Valves A commercial grade' evaluation was prepared. This evaluation demonstrated l

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,, ATTACatDtf to Ltr Dated 11/20/89 Pese 4 of 8 that these valves were suitable for their intended safety function, including seismic requirements.

C. 30 AMP Circuit Breaker This breaker was removed and replaced with a QA Class I breaker.

D. Composite Rupture Disc 1

A commercial grade evaluation was prepared documenting the suitability of this item to perform its intended safety function.

E. 4 Pole Positive Action Switch A commercial grade evaluation was prepared documenting the suitability of this item to perform its intended safety function.

F. Square D Pressure Switch A commercial grade evaluation was prepared documenting the suitability of this item to perform its intended safety function.

C. 5400 Microfarad Capacitor The capacitor has been replaced with a QA Class I component.

H. 100 AMP Circuit Breaker A 100 amp circuit breaker was installed in the plant without adequate

- evaluation of its suitability to perform its intended safety function. . As part of the response to NRC Bulletin 88-10, documentation of this item was

! considered insufficient to establish traceability to the circuit breaker l manufacturer. A Justification for Cuntinued Operation remains in effect establishing that the potential failure of this item poses no adverse j safety impact on the plant.

'This breaker will be replaced with a qualified device in accordance with our response to NRC Bulletin 88-10 (Reference 2). ,

I. Foxboro 62H Relays j -A' commercial grade evt.luation har been prepared documenting the adequacy of-i these items including vendor correspondence certifying that the replacement

• items '<ai identical in form, fit, and function co the original relays.

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Ltr Deted 11/20/09 I Pese 5 of a Corrective Stens to be Taken'to Avoid Further Violations A Materials Engineering section was established at Prairie Island in l September,1989, to coordinate purchases and material control of all parts.

l This section will ensure that commercial grade items purchased after November <

l' 4,1988 are properly selected, reviewed, evaluated and documented before use ,

in safety related functions.

~ Date'When Full como11ance will be Achieved  !

Full compliance has been achieved.

References ,

1. 14tter dated 1/9/89 from D M Musolf (NSP) to the Dir of NRR titled:

" Dedication of-Commercial Grade Parts"  !

2.' Letter dated November 6, 1989 from T.M Parker (NSP) to the Dir of NRR '

titled:-" Response to NRC Bulletin 88-10, Supplement 1. Nonconforming ,

. Molded Case Circuit Breakers" '

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Violation No. II  !

10 CPR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Administrative Control Directive SACD 3.7 requires, in part, that NRC Bulletins, NRC Notices,10 CFR 21 Reports, and vendor supplied experience documents be reviewed to determine their applicability to plant design and function. If they. are applicable, they shall be assessed to determine if corrective action is required, and the results of thee o assessments shall be documented on Form 536. l i

Contrary to the above, as of October 25, 1988, the review and assessment of the following NRC Notices and vendor supplied experience documents, an ac.tivity affecting quality, were not accomplished in accordance with Administrative Control Directive SACD 3.7: 4 A. The licensee failed to perform an evaluation for applicabil.ty to Prairie Island of 17 Service Information Letters and Repair Service Information Issuarx.3s from the emergency diesel generator manufacturer, '

Colt Industries /Fairbanks Morse Engine Division, which had been received during the period April 22, 1971 through April 22, 1988.

B. Westinghouse Technical Bulletin 85 16 on feedwater control valve accessories, NRC Notice 84-83 on " Station Battery Problems," Gamma-Metrics May 1988 10 CFR Part 21 notification concerning the excore neutron flux detectors, and NRC Notice 88-46 on " Licensee Report of Defective Refurbished Circuit Breakers," were not assessed for applicability to Prairie Island.

This-is a Severity Level IV violation (Supplement I).

i Admission of the Allened Violation 1Rie review and assessment of the vendor-supplied experience documents, referenced in paragraph A of the violation, were not accomplished in L

accordance with Administrative Control Directive 5ACD 3.7.

We disagree with the statement that the items referenced in paragraph B of the violation were not. assessed for applicability to Prairie Island. These items were assessed; however, the NRC inspector disagreed with the conclusions of l the assessments.

Reasons for the Violation 1Rie reason for the violation was a lack of appreciation and understanding of' the documentation requirements for vendor-supplied experience documents.

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I ATTACR D T to ttr Dated 11/20/09 Page 7 of 8 Corrective Steos Taken and Results Achievej

-A. The Service Information Letters and Repair Service Information issuances from Fairbanks Horse have been formally evaluated as part of the Operating Experience Assessment Program. Awareness by system engineers has been raised such that we expect to capture all incoming vendor '

correspondence. For the Fairbanks Morse correspondence, in particular, routing from the vendor has been changed so that all correspondence comes to the Plant Manager and then to the Operating Experience .

Assessment group.

• B. With the exception of the Gamma Metrics 10 CFR Part 21 notification, all items referenced in paragraph B of the violation were reassessed.

We believe the inspector's concern with the Gamma Metrics 10 CFR Part 21 notification is that no Justification for Operation was prepared. A Justification for Continued Operation was prepared during the inspection. Corrective actions have been taken on Unit 2 and will be taken on Unit 1-during the refueling outage scheduled for January 1990.

Conclusions From Reassessments:

Westinghouse Technical Bulletin 85 Following the review of additional information not available to the inspector at the time of the inspection, the reassessment agreed with the original asressment.

IE Information Notice 84 83 - The overloading of DC buses is prevented by the-modification process. Procedures were updated in 1987 to flag the solvent use concerns outlined in the Notice.

NRC Information Notice 88 This issue is superseded by NRC Bulletin 88 10.

Corrective Stens to be Taken to Avoid Further Violations Until now, responsibility for operating experience assessment had been shared i by two groups, a plant group and a technical support group. A reorganization L 'is underway that will bring all operating experience assessment activities under one group within the plant staft'. This reorganization will result in:

- centralizing the collection of all vendor-supplied information in the 4

Operating Experience Assessment group l - better documentation of assessment scope and thought processes a product that is easily auditable The new organization will be fully functional by December,31, 1989.

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