Text

Insp Repts 50-335/95-17 & 50-389/95-17 on 951204-15. Violations Noted.Major Areas Inspected:Procurement Engineering W/Focus on Commercial Grade Dedication & Item Substitution of safety-related Procurement Items
	ML17228B382
Person / Time
Site:	Saint Lucie
Issue date:	01/05/1996
From:	Russell Gibbs, Moore R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML17228B380	List: ML17228B379; ML17228B381; ML17228B382;
References
	50-335-95-17, 50-389-95-17, NUDOCS 9601190460
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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIElTASTREET, N.W., SUITE 2900

ATLANTA,GEORGIA 303234199

Report Nos.:

50-335/95-17

and 50-389/95-17

Licensee:

Florida Power

and Light Company

9250 West Flagler Street

Hiami,

FL

33102

Docket Nos.:

50-335

and 50-389

Facility Name:

St.

Lucie Plant Units

1 and

2

Inspection

Conducted:

December 4-15,

1995

License Nos.:

DPR-67

and NPF-16

Inspector:

. Moore

+go

Date Signed

Inspector:

R. Glbbs

Approved by:

. Cast

, Chief

Engineering

Branch

Division of Reactor Safety

ate Signed

Date Signed

SUMMARY

Scope:

This routine,

announced

inspection

was conducted

in the area of procurement

engineering.

The inspection

focussed

on commercial

grade dedication

and item

substitution of safety related

procurement

items.

(IP 38703,

IP 35750)

Results:

In the areas

inspected,

one violation with three

examples

was identified;

Violation 50-335,389/95-17-01,

Failure to Follow Procedures

for Material

Controls

(paragraphs

3.2, 3.3, 3.4. 1).

One example resulted

in the

installation of an unqualified diode in a

RCS

Gas Vent system safety related

solenoid valve.

Each of the examples

was attributable to an interface

deficiency in the procurement

or materials

issue process.

With the exception

noted

above,

procurement

and issue of safety related

equipment

was adequate.

Procurement

engineering

evaluations

provided adequate

technical

and quality requirements for material

upgrades

and substitutions.

gA oversight

was adequate.

Enclosure

2

960ii90460 960i05

PDR

ADOCK 05000335

6

PDR

Persons

Contacted

REPORT DETAILS

W. Bladow, guality Hanager

W. Bohlke, Vice President,

Nuclear Engineering

and Licensing

B. Dawson,

Licensing Hanager

A. DeRoy, Haintenance

Projects

D. Dietz, Licensing

J. Geiger,

Vice President

Nuclear Assurance

J.

Hoge, Supervisor

Procurement

Engineering

T. Kreinberg,

Hanager Nuclear Haterials

Hanagement

J.

HcHey,

Juno

Beach

A. Henocal,

Haintenance

Program Department

Head

K. Hohindroo, Chief Site Engineer

H. Paduano,

Hanager Licensing

B. Parks, guality Department

D. guilty, Nuclear Haterials

Hanagement

Supervisor

G. Regal,

Chief Procurement

Engineer

D. Sager,

Vice President

St. Lucie

J. Scarola,

Plant General

Hanager

T. Schiffley, Licensing Hanager

R.

Symes, guality Hanager,

Juno

Beach

K. Van Oeveren,

Principal

Engineer

C. Wasik, Licensing Engineer

J. West, Operations

Hanager

.* R. Winnard, Licensing Engineer

I

Other license

employees

contacted

during this inspection

included

technicians,

engineers,

and administrative personnel.

NRC Personnel

2.0

H. Hiller, Resident

Inspector

D. Prevatte,

Senior Resident

Inspector

Attended exit interview.

Acronyms

and abbreviations

are identified in paragraph

5.0.

Background

The procurement of safety related

items at St.

Lucie is

a multi-function

interdepartmental

process.

Procurement

Engineering

(PE) establishes

the

technical

and quality requirements

for the purchased

item which are

documented

in a technical

evaluation.

Nuclear Haterials

Hanagement

(NHH) incorporates

these

requirements

into purchase

documentation

transmitted to the supplier.

guality Control

(gC) receipt inspection

verifies the acceptance

criteria established

by

PE when the material is

received

on site.

Acceptance criteria were also verified on some

Enclosure

2

applications

by

a maintenance

post-issue

dedication during installation

of the purchased

item in the plant.

These applications

were identified

by a material field dedication

tag attached

to the item during initial

receipt inspection.

Organization

and process

evolutions at St. Lucie have introduced

challenges

to the procurement

process.

The in-line guality Assurance

(gA) review was discontinued

in March,

1993.

The independent

review was

assumed

by PE.

The procurement

procedures

were changed

in February,

1994, to delete

an intermediate tier of gA program implementing

procedures.

In late

1993,

PE converted to an electronic data

base

system,

Passport.

In 1995,

NMH and maintenance

converted to Passport.

This inspection

reviewed the licensee's

safety related

procurement

activities related to commercial

grade dedication

(CGD)

and item

equivalency evaluations

(IEE) for item substitutions.

Additionally

reviewed were

PE staff training and qualification, warehouse

identification and storage of materials,

and

gA oversight of the

procurement activities.

The inspection

included review of procurement

and maintenance

documentation,

interviews with personnel,

warehouse

walkdown,

and observation of gC receipt inspection activities.

The

following provided regulatory guidance for this inspection:

Regulatory Guide

(RG)

1. 123,

gA Requirements

for Control of Items

and Services for Nuclear

Power Plants

ANSI N45.2. 13-1976,

gA Requirements

for Control of Items

and

Services for Nuclear

Power Plants

3.0

NRC Generic Letter 91-05,

Licensee

Commercial

Grade

Procurement

and Dedication

Programs

FPL Topical guality Assurance

Report

(FPLT(AR 1-76A)

Procurement

Engineering

The inspectors

reviewed the qualification and experience

of personnel

assigned

to the procurement

engineering

organization at St. Lucie.

The

staff included

a supervisor

and ten engineers

and technicians,

some of

which were

on temporary assignments.

The qualification review included

training, certification records,

and personnel

interviews.

Personnel

in

procurement

engineering

were required to complete

a certification

program which was outlined in FPL Standard

STD-PE-001,

Rev.

4, Nuclear

Engineering

Standard,

Procurement

Engineering Responsibility.

The

standard

specified

a management

evaluation of personnel

experience

and

training.

This certification process

evaluated

personnel

knowledge of

industry standards

(e.g.

ASHE Code,

IEE standards,

ANSI and

ASTH

Standards,

EPRI standards,

etc), reactor plant systems,

St.

Lucie

technical specifications,

corporate

and site guality Assurance

Instructions,

and guidance related to the dedication of commercial

grade

Enclosure

2

3.1

3.2

materials.

Host of the certification process

was

based

on

a combination

of work experience

and self study in these

areas.

With the exception of

two procurement

analysts,

the

PE staff had technical

college degrees.

One of these

analysts

had

a non-technical

college degree,

and extensive

nuclear

navy and industry experience

in procurement

engineering.

The

other individual

had

an associates

degree

from a technical

school,

and

extensive

industry experience

in the procurement

engineering function.

All of the

PE staff had at least three years

experience

in procurement

engineering

at St. Lucie,

and other industry experience

which

established

the basis for their qualifications.

Based

on

a review of

certification records

and interviews with these individuals,

as well as,

the technical

review of their work discussed

in paragraph

3.2, the

inspectors

concluded that the procurement

engineering staff was

adequately qualified for their assigned responsibilities.

gC Receipt Inspection

The inspectors

reviewed the qualification of the licensee's

gC receipt

inspectors

and observed

the performance of receipt inspection for a

commercial

grade procurement.

There were three

gC receipt inspectors

at

St. Lucie.

They were certified as

gC Level II receipt inspectors

in

accordance

with ANSI N45.2.6, gualifications of Inspection,

Examination,

and Testing Personnel

for Nuclear

Power Plants.

The inspector

observed

the receipt inspection of 50 relay sockets

under Purchase

Order

00012014,

receipt inspection report

(RIR) 038770

and procurement

evaluation

039893.

The acceptance

criteria specified

on the procurement

evaluation

were verified with the exception of insulation resistance

testing which was to be field verified prior to installation.

Field

verification tags

were attached to each

socket referencing the post-

issue, dedication requirement.

The inspectors

concluded the

gC receipt

inspectors

adequately verified the specified

acceptance

criteria for the

dedicated relay sockets

and demonstrated

appropriate attention to

quality standards.

CGD and

IEE Sample

The inspectors

reviewed procurement

documentation for commercial

grade

dedication

and item substitution of safety related

equipment

and

materials

over the previous

two years.

The documentation

was reviewed

to determine if equipment critical characteristics

were adequately

defined

and verified.

Acceptance criteria were verified by gC receipt

inspection

and

by maintenance

via a post-issue

dedication.

The

following procurement

evaluations

were reviewed:

CGDs

039604

035757

039443

038344

034329

035804

039518

040101

035196

037298

039669

038966

035199

037299

040298

038962

035628

038082

038781

038956

035736

038753

037931

038942

Enclosure

2

038941

037705

039928

037361

039626

036713

039624

039431

038564

IEEs

031602

034944

037650

039553

033744

034945

038639

039701

034050

035508

038682

039716

034097

036247

038911

039819

034751

037183

039087

034889

037452

039264

The inspectors

concluded

the technical

evaluations

adequately

defined

the critical characteristics

of the associated

procurement

items

and

established

appropriate

technical

and quality requirements.

Item

equivalency evaluations

adequately

compared

the critical characteristics

between

the original

and substitute

items.

With the exception discussed

in the following paragraph,

the specified

acceptance

criteria were

adequately verified by the receipt inspection or post-issue field

verification activity.

The inspectors

concluded that

PE provided

adequate

technical

support for procurement of safety related

equipment

and materials.

The inspectors identified one example in which a required post-issue

dedication

was not performed

by maintenance/construction

services.

Work

orders

95020550,

95020551,

95020552

and 95020545,

dated

November 27,

1995, installed unqualified diodes in safety related

Reactor Coolant

System

(RCS)

Gas Vent System solenoid valves,

V-1460, V-1461, V-1462,

and V-1463.

The commercial

grade dedication

procurement

evaluation

039431

and material dedication

tags

were attached.

The inspection

also included

a sample of

items with required shelf life or in-storage

maintenance

requirements.

With the exception of a deficiency related to in-storage

maintenance

requirements,

the inspectors

concluded that the material identification

and control in the warehouse

was good.

During the warehouse

walkdown the inspectors

identified regulated

power

source devices with an in-storage

maintenance

requirement

which was not

incorporated into the warehouse

shelf life program.

Commercial

grade

procurement

evaluation

036828 required biannual

energization of the

devices to maintain the shelf life.

The items were purchased

on

PO

0007466,

dated

December

13,

1994,

and

PO 0007379,

dated October 27,

1994.

The items were not tagged to indicate this requirement

nor

included in the periodic maintenance

program for warehouse

material

as

required

by procedure

IP-1102,

In-Storage

and Shelf Life Maintenance

Program,

revision 0.

This deficienc

is identified as

an

exam le of

Violation 50-335

389 95-17-01

Failure to Follow Procedures

for Material

Controls.

3.4

Problem Identification and Resolution

3.4.1

The inspector

reviewed the licensee's

activities related to the

identification and resolution of deficiencies

and discrepancies

identified during the receipt inspection

and procurement

process.

The

review included Supplier Deviations Notices

(SDNs), Deficiency Reports

(DRs),

and

ST. Lucie Action Reports

(STARs)

Supplier Deviation Notices

Supplier Deviation Notices are

used at St.

Lucie to resolve

vendor

exceptions

to contract/purchase

order requirements prior to material

shipment.

As such,

these notices

serve

as corrective action documents.

The inspectors

requested

the licensee

to provide

a copy of all

SDNs

issued

in the last two months in order to support

a review for

appropriateness

of corrective actions.

The following Supplier Deviation

Notices were reviewed

by the inspectors

during the inspection:

Enclosure

2

SL-95-006-0

SL-95-034-4

SL-95-033-4*

SL-95-027-4*

SL-95-033-5

SL-95-034-5

SL-95-033-5*

Not resolved

as of December

8,

1995.

The inspectors'eview

of these

SONs determined that vendor deviations

were being appropriately resolved with one exception.

The exception

was

SDN SL-95-034-05.

Upon receipt of purchase

order

(PO)

12173,

the vendor notified the licensee that fuses to be supplied

under

PO 12173 (stock codes

0199809-1

and 0036616-1)

did not meet the purchase

order specifications for time-current characteristics.

For example,

vender testing of a sample of the fuses

determined that the fuses

would

not break the circuit in the required

amount of time when subjected

to

200% and

250% of the rated current.

SDN SL-95-034-5

was written on

November 21,

1995 to obtain

a resolution to this vendor exception.

The

SDN was resolved

on November 25,

1995, allowing the vendor to ship the

fuses

based

on

PE evaluations

040129 (for stock code 0036616-1)

and

040130 (for stock code 0199809).

Review of these evaluations

and

walkthrough of the material in warehouses

1 and

G-2 revealed

two

problems which were presented

to the licensee for resolution:

PE evaluation

040130 concluded that the fuses

(stock code 0199809-

1) were acceptable

for non-safety related application,

however,

no

action

was taken to downgrade

the material to the licensee's

non-

safety

Procurement

Classification

PC-3 or PC-4.

As

a result,

the

fuses

were found in

a ready for issue status

in warehouse

G-2

tagged with a safety related

(PC-1) tag.

The end

use of these

fuses

was,

however, specified

as non-safety in the Passport

computer program,

which would have prevented their use in safety

The licensee

took action prior to the end of

the inspection to downgrade

and tag these

fuses

as

PC-3 material.

PE evaluation

040129 concluded that the vendor should ship the

fuses

(stock code 0036616-1),

and that further engineering

evaluation of the specific safety related application would be

required prior to installation in plant equipment.

As

a result,

the procurement

engineer took action via a computer

message

to

place the fuses

"on

gC hold" upon receipt.

Investigation into

this material

by licensee

personnel

and the inspector determined

that the fuses

had not been placed

"on

gC hold" as directed

by the

PE evaluation,

but had

been received,

gC receipt inspected,

and

made ready for issue

as safety related

(PC-1) material.

Additionally, it was identified that two of the fuses

had

been

drawn,

and installed in a non-safety related application

(main

feedwater regulating valve circuitry).

Following identification

Enclosure

2

of this condition, the licensee

placed the fuses in stock "on hold

pending

PE evaluation,"

and issued

STAR 952127 to identify the

root cause of this problem

and to document corrective. actions.

Further investigation of this problem by the licensee

determined

that the computer

message

to place the material

"on

gC hold" was

never transmitted to the

gC receipt inspection

group due to a

computer

(Passport)

programming error.

This programming error was

generic to both the Turkey Point site

and to the St. Lucie site.

This error resulted

in twenty three additional potential

problems

at St.

Lucie and seventeen

potential

problems at Turkey Point.

The licensee

took immediate action to correct the programming

error,

and investigate all forty potential

problems at both sites.

No additional material deficiencies

at either site were caused

by

this computer

programming error.

The failure to follow

en ineerin

instructions to

lace safet

related material

"on

C

hold"

endin

further

PE evaluation is identified as

exam le of

Violation 50-335

389 95-17-01

Failure to Follow Procedures

for

Material Controls.

3.4.2 Receipt Inspection Deficiency Reports

Receipt

Inspection Deficiency Reports

are

used at St.

Lucie to resolve

deficiencies

discovered

during receipt inspection of materials

by gC

inspection.

As such,

these deficiency reports

serve

as corrective

action documents.

The inspectors

requested

the licensee to provide

a

copy of all deficiency reports

issued in the last two months in order to

support

a review for appropriateness

of corrective actions.

The

following deficiency reports

were provided by the licensee

and reviewed

by the inspectors

during the inspection:

D0030404

D0034107

D0036163

D0037720

D0031742

D0029916

D0029302

D0030715

D003879

D0032839

D0029005

D0032240

D0033907

D0037771

D0029153

D4348411

D0031743

D0029005

D0031729

D0029922

D0031626

D0031605

D0035584

D0036609

D0037601

D0037668

D4348433

D0030389

D0028011

D003874

D0036520

D0031626A

D0027431

D0034715

D0037769

D0037398

D4348432

D4348034

D0030719

D0034015

D003875

D0034972

D0037649

D0029155

The inspectors'eview

of these deficiency reports did not identify any

weaknesses

concerning corrective action for deficiencies identified

during the receipt inspection

process.

Enclosure

2

it

~

3.4.3

STARs

STARs were the station process for the identification and resolution of

plant problems.

The inspectors

reviewed

a sample of STARs with a cause

code of material deficiency.

The following STARs related to material

deficiencies

were reviewed:

950088

950472

950265

50654

950997

951379

950308

950843

950343

950871

951016

950133

950462

950207

950570

950271

951018

950084

950806

950326

951988

950398

951218

950745

950206

950568

950268

950772

951255

950124

950309

950041

950368

950972

951358

3.5

The inspectors

concluded that the issues

identified in the above

STARs

were adequately

resolved.

Control of Procurement

Database

The inspectors

reviewed the licensee's

control of the materials

data

base

which provided description,

specifications

and safety

classifications of specific items.

As previously noted,

the database

was recently converted to an electronic system,

Passport.

The previous

Haterials

and Supply

(H&S) catalog,

which was primarily a manual

data

base

was converted to the Passport

system.

The conversion resulted

in

numerous

item description discrepancies

which were being resolved

through

a

PE catalog review process.

'uring several

of the staff interviews, the previous

procurement

data

base

process

was discussed.

The interviews indicated that technical

changes

to the

H&S catalog

(which included the ordering data for

material

purchases)

could

be made

by pen

and ink annotation

on

a hard

copy of the catalog,

without technical justification being provided for

the change.

The inspectors

reviewed

a sample of the

H&S catalog

changes

to determine if changes

in technical

requirements

had occurred without

adequate justification.

Changes to the following H&S stock codes

were

reviewed

by the inspectors:

570-28480-7

772-74237-0

578-14250-5

579-38918-1

570-03490-8

772-72872-5

578-93550-5

579-63676-5

570-24336-1

579-61445-1

578-92076-1

570-13137-7

579-05308-5

578-36850-3

Review of the changes

to these

stock codes

concluded that all of the

changes

were supported

by adequate

technical justification.

A relatively detailed review of the capabilities of the computer

based

Passport

system

was conducted

during the inspection.

The Passport

system provided easy

and direct communication

between the various

material

groups, facilitated the procurement

process,

minimized material

Enclosure

2

3.6

errors,

and allowed easy

access

to technical

information on material

purchasing,

stocking

and usage.

The inspectors

concluded that the

implementation of this system

was

an overall strength of the licensee's

material

procurement

and control program.

During the course of the inspection,

the inspectors

noted the

development of Bill of Materials

(BOHs) for many of the plant

components.

These

BOMs included

a pre-engineered

listing of piece parts

used in assembly of components,

which included the item technical

description,

safety classification,

stock code,

and stocking

information.

BOHs have

been developed for approximately

50% of the high

use equipment

in the plant.

The inspectors

considered

BOH development

to be

a strength of the licensee's

material

program,

due to the fact

that it pre-engineers

the piece parts,

makes identification of piece

parts easier

and faster,

maintains

a minimum amount of high use parts

available,

and minimizes the chance for unqualified parts

being

installed in the plant.

QA Oversight

The inspectors

reviewed the

QA oversight of safety related

procurement

activities at St. Lucie for the previous

two year period.

Oversight

activities included audits

and performance monitoring (p-mons)

surveillance.

The following audits

and p-mons were reviewed:

QAS-NMM-94-1P

QSL-OPS-95-18

P-mon 95-048

QSL-OPS-95-13

P-mon 95-028

QSL-OPS-95-11

P-mon 94-102

QAS-NHH-95-01

October

28,

1994

November

14,

1995

July 14,

1995

June

28,

1995

November 22,

1995

QAS-94-1P evaluated

the quality of the procurement

documentation

following the discontinuing of the in-line QA review.

No significant

deficiencies

were identified.

P-mon 95-048 identified inconsistencies

between

the work practices

and procedures

for construction services

and

plant maintenance

organizations.

Both organizations

were responsible

for performing post-issue

dedication.

Construction services failed to

perform the post-issue

diode dedication referenced

in the violation

identified in this report.

P-mon 94-102 identified

a deficiency in the

work order documentation of "qualitative" post-issue

dedication

activity.

The diode example

was failure to perform

a "quantitative"

measurement.

QAS-NHH-95-01 was the only comprehensive

audit of the procurement

process.

The audit conclusion

was that the requirements

of the

QA

program

as described

in the

FPL Topical

QA Report were not adequately

addressed

by procedures

and that existing procedures

were not adequately

Enclosure

2

10

4,0

implemented.

The audit identified no examples

in which unqualified

equipment

was installed in the plant.

As

a result of the audit

findings, the licensee initiated

a management

task force chaired

by

a

vice president to review the

FPL procurement

process.

The task force

activities were scheduled for completion

by the end of 1995.

The

inspectors

concluded that

QA oversight of safety related

procurement

activity was adequate.

Exit Meeting

The inspection

scope

and results

were summarized

on December

15,

1995,

with those individuals indicated in paragraph

1.

The inspector

described

the areas

inspected

and discussed

in detail the inspection

finding below.

There were

no dissenting

comments

received

from the

licensee.

Proprietary information in not contained

in this report.

Violation 50-335,389/95-17-01,

Failure to Follow Procedures

for Material

Controls.

5.0

Acronyms

and Abbreviations

ANSI

American Nuclear Standards

Institute

BOM

Bill of Materials

CGD

Commercial

Grade 'Dedication

Dg

Deficiency Report

FPL

Florida Power L Light

IEE

Item Equivalency Evaluation

NHM

Nuclear Materials

Management

PE

Procurement

Engineering

PO

Purchase

Order

QA

Quality Assurance

QC

Quality Control

RCS

Reactor Coolant System

SDN

Supplier Deviation Notice

STAR

St. Lucie Action Request

WOs

Work Orders

Enclosure

2

ML17228B382

Text

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