ML20210F424

Ack Receipt of 870126 Response to NRC Request for Addl Info Re Insp Repts 50-382/84-42,50-382/85-01 & 50-382/85-05

ML20210F424
Person / Time
Site:	Waterford
Issue date:	02/04/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8702110066
Download: ML20210F424 (2)

See also: IR 05000382/1984042

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In Reply Refer To:

Docket: 50-382/84-42

50-382/85-01-

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50-382/85-05

Louisiana Power &'-Light Company

ATTN:

J. G. Dewease, Senior Vice President

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Nuclear Operations

N-80

317 Baronne Street

New Orleans, Louisiana

70160

Gentlemen:

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Thank you for your letter of January 26, 1987, in response to 'our

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letter requesting additional infomation regarding NRC Inspection'

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Reports 50-382/84-42, 50-382/85-01, and 50-382/85-05 dated October 27, 1986.

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We have reviewed your reply and find it responsive to the questions-raised in

our letter. We will review the implementation of your corrective actions

during a future inspection to determine that full compliance has been achieved

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and will be maintained.

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Sincerely,

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Y:infnel Si,md Gy

11. E. Gagi!ardo

J. E. Gagliardo, Chief

Reactor Projects Branch

cc:

Louisiana Power & Light Company

ATTN:

G. E. Wuller, Onsite

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Licensing Coordinator

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P. O. Box B

Killona, Louisiana

70066

Louisiana Power & Light Company

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ATTN:

N. S. Carns, Plant Manager

P. O. Box B

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Killona, Louisiana

70066

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Louisiana Power & Light Company

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cc:

Middle South Services

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ATTN: Mr. R. T. Lally

P. O. Box 61000

New Orleans, Louisiana

70161

Louisiana Power & Light Company

ATTN:

K. W. Cook, Nuclear Support

and Licensing Manager

317 Baronne Street

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P.' O. Box 60340

- New Orleans, Louisiana'

70160

Louisiana Radiation Control Program Director

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RPB

D. Weiss, RM/ALF

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R. D.' Martin, RA

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NEW ORLEANS, LOUISIANA 70160

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January 26, 1987

W3P86-2806

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U.S. Nuclear Regulatory Commission

ATTN: Document Control D'sk

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Washington, D.C. 20555

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JAN 2 91987

Subject: Waterford 3 SES

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Docket No. 50-382

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License No. NPF-38

NRC Information Request, October 27, 1986

Reference: NRC letter dated October 27, 1986 Requesting Additional

Information regarding NRC Inspection Reports 84-42, 85-01 and

85-05.

By the referenced letter the NRC requested additional information

concerning certain spare part procurement issues at Waterford 3.

LP&L requested and received an extension of the original 30 day response

period in order to review the issues in detail and provide time to meet

with the NRC staff prior to submittal of the response.

On January 20, 1987 we met with Messrs. L. Constable and J. Boardman of the

NRC staff. During the meeting we discussed in detail the basis for the

additional information request as well as LP&L's initial review findings.

We wish to commend the staff for their professional attitude and cogent

comments which enabled resolution of these issues.

Enclosed please find LP&L's response to the five questions presented in the

referenced letter. We believe that this response, which addresses the

NRC's comments from the January 20 meeting, provides the basis for closure

of the procurement related issues.

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Should you have any further questions on this matter please feel free to

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contact me.

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Very truly yours,

K.W. Cook

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Nuclear Safety and

Regulatory Affairs Manager

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KWC:MJM:pmb

E.L. Blake, W.M. Stevenson, G.W. Knighton, J.H. Wilson, R.D. Martin,

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cc:

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'L. Constable, J. Boardman, NRC Resident Inspectors Office (W3)

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"AN EQUAL OPPORTUNITY EMPLOYER"

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Paga 1 of 13

LP&L Response to NRC Region IV Letter dated October 27, 1986

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NRC request for additional information on -

Subject -

Violation No. 8442-01

Inadequate Procedures for

Procurement of Spare Parts for Safety-Related.

Applications.

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Reference -

LP&L letter W3P85-0825 dated 4/10/85 -

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rgsponsetoViolation 8442-01.

REQUEST: Describe the program for re-establishing the acceptability

of safety-related items which were previously procured on

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down-graded purchase orders, and that have been installed in

safety-related systems, components and st ructures.

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RESPONSE: On November 1 and November 26, 1984 Waterford 3 management

met with Region-IV to review the issue of commercial grade

spare parts for use in safety related applications (this

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issue encompassed the above question of installed commercial

grade salaty-related parts). During these wide-ranging

discussions, most aspects of the commercial grade spare

parts isn'te were addressed and, to our understanding,

resolved with the Region.

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As we noted on November 26, 1984 LP&L's then current

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precurement procedures met the intent of 10CFR50 Part 21 with

respect to the " dedication" associated with procurement and

use of commercial grade safety related spare parts. For

instance.

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1.

Dedication occurs at the time of the order,

2.

Purchase orders for commercial grade spare parts

include certificates of compliance from the

supplier which attest to meeting the purchase

order requirements, and

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3.

Purchase orders for commercial grade spara parts

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include a "no substitution" clause.

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Additionally, LP&L's then current procurement procedures met

the intent of ANSI N18.7, Paragraph 5.2.13, " Procurement and

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Materials Control".

For instance, engineering evaluations

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were routinely performed by requirements engineers. Further

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details of the Waterford 3 procedural history for evaluating

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the acceptability of commercial grade parts is discussed in

Attachment 1.

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Since our meeting, the commercial grade spare parts

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dedication process had been strengthened through refinement

of the Spare Part\\ Equivalency Evaluation program.

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As you will recall, LP&L management was curious as to how

our procurement program in late 1984 would rate with other

programs in the nuclear industry. To that end, we surveyed

11 nuclear utilities (7 of which had operational units at

that time) and asked them if their procurement programs

included certain,of the elements contained in LP&L's program

in 1984. The results, previously presented to Region IV,

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were as foll,ows:

Included in

Procurement

Procurement

Requirement

Program

Receipt inspection performed on

100%

commercial grade safety related

spares

Certificates of compliance imposed

82%

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on suppliers

Engineering evaluation (of some type)

73%

performed

Connercial grade spares bought from

27%

approved suppliers (QSL)

"No substitution" clause imposed

18%

on suppliers

As we noted on November 26, 1984 the procurement program for

Waterford 3 was generally ahead of the majority of the

industry and merited recognition rather than censure.

It is

our understanding that these survey results and conclusions

were later verified by Region IV.

During the period immediately prior to November, 19'84,

another NTOL nuclear utility had conducted an extensive

investigation into the use of commercial grade material in

safety-related applications. Basically, the utility

reviewed all commercial grade purchase requisitions to

identify any which were intended for use in safety-related

systems, and, for those so identified, conducted an

engineering evaluation to determine acceptability of the

application. At great time and expense the study showed

that all installed commercial grade components were

acceptable for their safety-related application.

(It is

worthwhile to note that the above program consisted of a

100% review of all harsh environment EQ parts (the large

majority of the effort) and a sampling of four safety

systems for non-EQ parts. Waterford 3's EQ program provided

essentially equivalent coverage for EQ parts.)

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During the November 26, 1984 meeting we noted that LP&L did

not intend to conduct a similar program. 17ue other

utility's results had demonstrated that an enormous

investment in personnel and money would lead to virtually no

benefit when investigating the use of commercial grade parts

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in safety-related applications. We had, however, recently

implemented the SPEER process, the initial results of which

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could be usgd to estimate the number of inappropriate

safety-related applications of commercial grade parts.

(As

noted in the response to Question II, Spare Parts

Equivalency Evaluation Reports (SPEERs) and Part Quality

Determination (PQD) forms are used by LP&L to dedicate che

use of a non-safety related component provided that the

safety-related function is not degraded.) As we discussed

with the Region on November 26, 1984, the number of

unsuccessful (i.e., could not be dedicated) SPEERs was very

low. Subsequent experience continues to confirm this fact.

During 1984-1985, of 100 SPEERs conducted by the Waterford

plant staff, only 3 were determined to be unsuccessful.

To provide additional confirmation of the end-use

acceptability of downgraded spare parts, LP&L initiated

SPEERs for the nine downgraded procurement packages

identified in Inspection Report 84-42 (dated February 26,

1985). The SPEER results, which were documented in.

W3P85-0825 (dated April 10, 1985), indicated that the spare

parts in question were acceptable for their intended use.

For the reasons cited above, as well as subsequent

operational experience, LP&L is confident that the spare

parts procurement process is adequate, meets the applicable

regulations and provides assurance that no significant

safety concern exists with respect to installed spare parts,

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Pega 4 of 13

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ATTACHMENT 1

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Acceptability Evaluation

UNT-8-001, Preparation of Station Procurement Documents, is the prime

procedure for determining the safety classification of spare parts,

preparing purchase orders and evaluatjng the acceptability of a spare part

for its end-use application. The propedure was first issued on May 31,

1979 as Revision 0 and is currently in Revision 9.

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Revisions 0-3 (5/31/79 - 7/.20/82)

NOTE: Revision 1 does not exist.

Although some particulars changed, through this period a Spare Parts Group

(SPG) was responsible for performing evaluations to establish the safety

classification for spare parts to be used in systems turned over from

Ebasco.

It was required that each major component and subcomponent (as

applicable) be separately identified on a major component data sheet or

subcomponent data sheet along with its safety classification and

justification.

Subcomponent data sheets were required when the SPG

evaluator determined that a subcomponent of a safety-related major

component should be classified as non-safety.

For each part to be ordered, the procedure required that a parts data sheet

be completed.

In addition, if a part of a safety-related major component

or subcomponent should be classified as non-safety related, the SPG

evaluator was to complete a part evaluation sheet which, through a series

of questions, established the safety classification / requirements for the

part.

The down-grading process was an inherent part of the SPG process.

It would

not be unusual for major safety-related components to have subcomponent

parts evaluated as non-safety. While the down-grading was intended to

occur at the beginning of the procurement process, Revisions 2-4 explicitly

allowed re-evaluation at any time provided the subcomponent/ parts

evaluation sheets contained adequate justification.

Revision 4 (7/21/82 - 1/3/84)

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At this time a formal Procurement Grade Level (PGL) classification was

introduced to further refine the safety classification of spare parts.

The

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PGL classification was documented on a PGL Evaluation Sheet.

Revision 4 also introduced a new process to justify the use of PGL-3 and

PGL-4 (commercial grade) parts in safety-related equipment. Such use was

allowed providing an analysis demonstrated that the quality or safety of

the safety-related equipment was not degraded by installation of the part.

Three types of justification were allowed;

a.

Duplication of original application (i.e. the original equipment

was commercial grade),

b.

Engineering analysis (i.e. essentially a repetition of the

original design process), and

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Type testing.

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The justification could be performed as part of the original purchase order

or at any other time. Documentation was required on the Analysis and

Justification For Use of PGL 3 & 4 Parts in Safety Applications form.

Revisions 5-9 (1/4/84 - Present)

With Revision 5, UNT-8-001'was entirely rewritten, and re-titled Processing

of Procurement Documents. A number of major changes were introduced at

this time.

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In this process, plant staff are responsible for originating Material /

Service Request (MSRs). Requirements Engineers (REs) in Procurement then

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compare the MSR with previous procurement documents including

specifications and drawings.

If the requested parts differ from the

previous purchase, the MSR is returned to the originator (or retained by

the RE, depending on the procedure revision) who may clarify the MSR,

initiate a SPEER or initiate an SMR.

Revision 5 also introduced a large degree of conservatism in safety

classification.

If a requested part or service was dedicated for use in a

safety-related system, structure or component the part or service was to be

treated as safety-related.

Supplier exceptions to technical or quality requirements of a purchase

order are recorded on a Major Exceptions form.

For other technical or

quality changes a Major Change form is used. The MSk originator or RE is

required to evaluate the exception or change (on a SPEER if necessary) and

forward the review for quality reviewer approval.

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Paga 6 of 13

II.

NRC request for additional'information on -

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Subject -

Violation No. 8442-01, Inadequate Procedures for

Procurement of Spare Parts for Safety-Related

Applications.

Reference -

LP&L' letter W3P85-0825 dated 4/10/85 -

response to Violation 8442-01.

REQUEST: Describe how existing procedures assure that

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previously grocured items which are not installed (in

storage) ake approved by SPEER prior to use in

safety-related applicaticns.

RESPONSE: LP&L has used the receipt inspection process

(most recently, QI-010-006) for the procurement program.

Items received were. inspected to verify that the purchase

order requirements were met. Sheuld requirements not have

been set, a Discrepancy Notice (DN) was written. When the

DN was resolved the item was placed in stores with the

applicable quality level established. Safety-related items

were green-tagged and were readily identifiable as

satisfactory for installation in safety related systems.

Items having a lower quality level could not receive a green

tag.

Currently any ites purchased as non-safety related could not

have been issued from the warehouse, for use in a

safety-related application, without performance of an

engineering evaluation.

In accordance with UNT-8-011,

Stores, Issuing, Shipping & Receiving, safety-related items

are " green tagged" in the warehouse with appropriate quality

documentation. Upon receipt of a Request on Stores (ROS)

for a safety-related component, warehouse personnel are

required'to precisely match the requested item with the

stocked itea, including its safety classification. Should

the items not match, a process exists for determining the

acceptability for use of a component providing the

safety-related function is not degraded. UNT-7-021 and

UNT-8-011 describe use of a Part Quality Determination (PQD)

form completed by Plant Engineering. This form takes the

Engineer through the appropriate thought process including a

decision whether the item in question could be used even if

it had been bought non-safety-related. Depending on the

Fngineer's answer, a Spare Parts Equivalency Evaluation

Report (SPEER) may be generated.

This process was brought about by LP&L's conservative

approach to material / warehouse control;

i.e., if the item (s)

were to be used as replacement in a safety-related system or

component, then the item (s) had to have been stocked as

safety-related.

If this was not the case, a PQD was

generated, initiating the engineering evaluation process.

The procedures discussed above provide assurance that

previously procured commercial grade items are approved

prior to use in safety-related applications.

Pag 2 7 of 13

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III. NRC request for additional information on -

Subject -

Violation No. 8501-01, Licensee Failure to Have

Procedures to Assure Compliance with Waterford SES

Unit 3 Operations Quality Assurance Program,

Section 17.2.23, and FSAR Table 3.2.1, Note 12.

Reference -

LP&L' letter W3P85-1477 dated 9/19/85 -

response to Violation 8501-01.

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REQUEST: Describe aegions taken to ensure that procurement

activities'for safety-related items, including

installed items procured prior to the November 15,

1984, approval date of UNT-8-001, Revision 8, meet the

requirements"of Waterford 3 FSAR, Table 3.2-1, and

10CFR50, Appendix B.

RESPONSE: As discussed in the referenced letter, LP&L has included, in

the current revision of UNT-8-001, an explicit requirement

to review FSAR Table 3.2-1 in conjunction with procurement

activities. However, the implication of the NRC's question

is that procurement activities could be somehow deficient in

not referencing FSAR Table 3.2-1 in previous versions of

UNT-8-001.

This is not the case.

Procedure UNT-8-001, " Processing of Procurement Documents",

contains the LP&L requirements for procurement control. As

noted in the initial LP&L September 19, 1985 (W3P85-1477)

response on this subject, Requirements Engineers were

responsible for consulting the FSAR (among other documents)

to identify applicable purchase requirements. While an

explicit reference to FSAR Table 3.2-1 was not included in

UNT-8-001, it should be recognized that a multitude of

source documents existed to aid the purchase requisition

preparer in accurately determining the safety classification

of spare / replacement parts. For instance, a typical

requirement in UNT-8-001 (in this case, from Revision 7

dated August 28, 1984) directed that:

The Requirements Engineer is responsible for

researching previous purchase documents and associated

specifications and drawings to determine the

applicable requirements to apply to the Purchase

Requisition / Contract Requisition. He shall consult the

FSAR, LP&L QAM, LP&L commitments and other regulatory

documents to assure Procurement Documents reflect

current requirements.

UNT-8-001 is not a stand-alone procedure. Personnel

performing activities under UNT-8-001 are expected to work

under all applicable procurement-related procedures. One

such procedure in existence until February, 1985 is QP 4.12

" Determination of Safety Relationship of Spare or

Replacement Components, Parts, Materials, and Services".

This procedure applied to all LP&L personnel who originated

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Paga 8 of 13

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and reviewed purchase requisitions for spare or replacement

component parts, materials and services. As the title

implies, its purpose was, in part, to describe the basis for

evaluation of replacement part requirements. As such, it

directed the user to consider a number of source documents,

including the FSAR, in determining the safety classification

for replacement parts.

More importantly, both UNT-8-001 and QP 4.12 directed a

careful examination of the effect of a replacement part

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failure or

component o,ny1 function on the safety function of a major

r subcomponent. A typical series of questions

(which varied somewhat depending on the procedure and

revision) included:

I.

Will the failure or malfunction of the above-named part

in the above-named component (or sub-component)

adversely affect:

1.

The integrity of the reactor coolant pressure

boundary?

2.

The capability to shut down the reactor and

maintain it in a safe shutdown condition?

3.

The capability to prevent or mitigate the

consequences of accidents which could result in

potential offsite exposures comparable to the

guideline exposures of 10CFR, Part 1007-

II.

Will the failure or malfunction of the above-named part

adversely affect the function or performance of the

above-named component (or sub-component) or system?

III. Are there any technical, documentation, or quality

assurance requirements assoc.iated with this part?

Based on the responses to these questions the appropriate

safety classification is selected for the replacement part.

This type of "first principles" safety classification

process is more rigorous and extensive than a simple review

of FSAR Table 3.2-1.

FSAR Table 3.2-1 is a major component safety classification

system which seldom contains the level of detail necessary

to specify the safety classification of replacement parts.

At best it would be a ' minor aid to the preparer of a purchase

requisition (PR). Prior to November, 1984 the PR preparer

was required to repifcate the original purchase order

specification.

For instance, if the original equipment

purchase had been electrical equipment (e.g. cables, relays,

motors, switchgear) purchased as 1E then subsequent spare /

replacement purchases would duplicate the original. Should

original specifications not be available or not include

explicit details on a part, the evaluation process described

above would apply.

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The procurement process for the period covered by the NRC's

question adequately specified appropriate safety

classification for replacement parts. LP&L therefore feels

that no further action in this area is necessary.

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IV.

NRC request for additional information on -

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Subject -

Violation No. 8504-01 Inadequate Documentation

for Ebasco Safety-Related Ventilation Heating

System and Replacement Parts Used with Charcoal

Filters.

Reference -

LP&L' letter W3P86-0019 dated 2/14/86 -

response to Violation 8504-01.

REQUEST: Providethhhasisforacceptanceofinstalled

components and replacement parts on Ebasco purchase

order NY 403556.

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RESPONSE: During the NRC Inspector's visit that resulted in Violation

8504-01 certain documentation was not immediately available

for review.

Subsequently, the necessary documentation was

retrieved, the substance of which is dicussed below.

On June 22, 1976, an Ebasco Evaluation of the Industrial

Engineering and Equipment Company (INDEECO) facility was

performed and the vendor was found to be unsatisfactory.

These evaluation results were documented in Ebasco letter

VE-E-21-286 dated 7/26/76. Subsequently, upon satisfactory

corrective action by INDEECO, the facility was considered

acceptable (Ebasco letter VE-E-30-286-1 dated 9/23/76).

On November 18, 1976, a Vendor Quality Assurance Report

documented that corrective actions were being implemented at

the INDEECO facility and that production on Ebasco Purchase

Order NY 403556 had not begun.

Ebasco performed source surveillances at the facility from

November 18, 1976 to December 16, 1982 when it appeared the

order was completed. Equipment was inspected by Ebasco

before being released for shipment.

Review of the INDEECO files shows that the INDEECO QA

program was found unsatisfactory during a QA Program

Evaluation for another project (Laguna Verde) in 1978. A

supplier manufacturing / service facilities QA Audit report on

INDEECO (7/27/78) indicated that the facility itself was

" Conditionally Satisfactory". A letter from Ebasco to

INDEECO, dated August 4, 1978, further documents that the QA

Manual was unsatisfactory but the facility was conditionally

satisfactory.

Review of the files does not reveal documented acceptance of

the INDEECO QA Manual until October, 1982 - about 4 years

after the initial " unsatisfactory" determination. An

evaluation of the facility was done on 10/13/82 and the

facility was determined to be satisfactory.

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However, as stated above, the 4 year span when the INDEECO

QA Manual was disapproved applied to the Laguna Verde

Project.

INDEECO was still approved for Waterford 3 during

that period. Because the Ebasco QA Project for Waterford

allows procurement of hardware under a conditionally

satisfactory program, and since source inspections were

performed, QA Program requirements were satisfied and the

quality of the'corponents supplied on the subject purchase

order was not affected.

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Pags 12 of 13

V.

NRC request for additional information on -

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Subject -

Violation No. 8504-03, Licensee Procedures for

Maintenance of Equipment Qualification and

Procurement of Spare Parts.

Reference -

LP&L letter W3P86-0019 dated 2/14/86 -

response to Violation 8504-03.

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REQUEST: Describeaegionstakentoensurethatbeforethe

November 13, 1984, approval date of UNT-8-001, Revision

8, procured material met the final design

specifications and purchase order revision.

RESPONSE: As part of the original response to the subject violation,

LP&L committed to perfore a review of specification changes

and to assist in determining the impact of those changes on

plant procurement activities. These activities have been

completed as discussed below.

LP&L directed Ebasco to perfore a review of selected Gasco

purchasing specifications for~all technical changes to

Waterford 3 to determine changes made to the specifications.

The sample represents 33% of all safety-related/ seismic

Ebasco specifications. The sele ^cted Basco specifications

represented plant equipment for which numerous spare and

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replacement parts are required.

Upon receipt of the nasco

specification review results. LP&L discipline engineers

determined that all specifications reviewed by Ebasco

contained technical changes from revision to revision.

A 20% sample of plant procurement documents was reviewed to

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determine the effect of using Basco specifications in the

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procurement activities. The purchase requisition sample

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turned up approximately 200 plant purchase requisitions

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which listed in some form a selected Gasco purchase

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specification. These 200 requisitions were then reviewed by

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LP&L discipline engineers to determine what effect the

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nasco specification would have on the purchase document

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involved.

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Based on this, review, it was determined that the listing of

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Basco purchase specifications on plant purchase documents

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had little or no detrimental effect on the parts and

components being procured and that no further effort should

be expended on this activity. This conclusion was based on

the followingt

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1)

Most requisitions did not impose Ebasco

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specification requirements. The specification was

merely referenced as being previously applicable

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by an earlier Ebasco purchase.

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