ML20137E516
| ML20137E516 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/03/1986 |
| From: | Baker E, Kirsch D, Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20137E433 | List: |
| References | |
| 50-344-85-38, TAC-60659, NUDOCS 8601170267 | |
| Download: ML20137E516 (6) | |
See also: IR 05000344/1985038
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U. S. NUCLEAR REGULATORY COMMISSION
Report No.: 50-344/85-038
Docket No.: 50-344
Licensee No.: NPF-1
Licensee: Portland General Electric Company
121 S. W. Salmon Street
Portland, Oregon 97204
Facility Name: Trojan
Inspection at: Rainier and Portland, Oregon
Inspection Conducted: October 30-31, 1985
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Inspectors: , CP - 4,r/ / # I
D. F. Kirsch, Deputy DirectoY, Division of Resident, Dat'e
Reactor Projects and Engineering Programs
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E. T. Baker, Reactive Inspection Section ~Dath
Approved by: , 85
G. G. Z(ch,,/
q Chief, Vendor Program Branch Date
8601170267 860115
PDR ADOCM 05000344
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SUMERY:
Inspection during the period October 30-31,-1985 (Report No. 50-344/85-038)
. Areas Inspected: One inspector from the Vendor Program Branch, Office of
Inspection and Enforcement and one inspector from Region V ccaducted an
- announced inspection to review information concerning classification of
rocurements and verification.of vendor furnished Certificates of Compliance
-p(C of Cs). In addition, the licensee's response to the-four Unresolved Items
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'(URIs) identified in Report No. 50-344/85-025 were reviewed.
The inspection involved 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> by two (2) NRC inspectors.
Results: The inspection substantiated the Potential Enforcement Finding
previously identified in Report No. 50-344/85-025 in the area of safety-
related procurement. Of the four URIs identified in Report No. 50-344/85-025,-
URIs 344-85-025-05 ar.d 344-85-025-06 were closed and 344-85-025-03 and
344-85-025-04 remain open.
DETAILS
1. PERSONS CONTACTED
Portland General Electric Company (PGE)
J. Lentsch, Manager, Nuclear Safety and Regulation
- A. Olmstead, Manager, Quality Assurance
A. Ankrum,-Nuclear Engineer
M. Cooksey, Section Supervisor, Electrical Engineering
- Denotes those individuals who attended the exit meeting.
2.- -BACKGROUND INFORMATION
.The purpose of this followup inspection was to address concerns expressed
- in the licensee's response, dated October 14, 1985, to Report No. 50-344/85-025.-
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The concerns were that the inspection team performing the August 9 and
12-16, 1985 inspection had incorrectly interpreted the licensee's procurement
requirements and equipment classification system, and had overlooked some
information concerning the licensee's efforts to verify the validity of
vendor furnished C of Cs. In an effort to resolve these concerns, the l
inspectors discussed the concerns and the licensee's response with the
licensee, and reviewed the additional information provided by the
licensee in the aforementioned areas.
3. Potential Violation; 344-85-025-01 (Procurement)
a. Initial Inspection j
In order to select safety-related modifications to review for
procurement and post-installation testing, the inspectors requested a
listing of safety-related " requests for design change" (RDCs). A
computerized printout of RDCs titled "RDC Log (Q-List Sort)" was
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provided. The definition of "0-Listed" appearing on page G-8 of
Revision 10 of PGE's Nuclear Quality Assurance Program is stated
as: " ...The Q-List identifies a systems, structures, and
components which...have been detennined to be safety-related. The
Q-List enumerates safety-related systems, structures, and components
to which the QA program applies." Attachment E, " Guidelines For
Determination of Safety-Related Purchase Requisitions", to NPEP
300-1, " Procurement Procedures for Nuclear Power Plant Modifications
and Additions," states that if the purchase requisition is the
result of a safety-related RDC, the purchase requisition i; to be
considered safety-related. Based on this information, the
inspectors concluded that equipment being procured for the
safety-related RDCs reviewed was to be considered safety-related.
From the "Q-List" RDC Log provided, the inspectors selected ten ROCS
to review in depth, from procurement through post-installation
testing. From the ten RDCs, the inspectors selected ten components
and reviewed the procurement packages for these ten components (see
Table 1, pg 4 of Report 85-025). PGE had classified the components
as QA Code 0 which, under PGE's procedure NQAP-105, meant that PGE
could and did purchase the components without imposing any quality
program requirements on the manufacturer or evaluating the manufacturer's
quality assurance program. The components were accepted based on a
C of C from the manufacturer.
Regulatory Guide 1.123 (Rev. 1) " Qual'ity Assurance Requirements for
Control of Procurement of Items and Services for Nuclear Power
Plants," which endorses ANSI N45.2.13-1976, which PGE committed to
in their FSAR, allows purchases based on C of Cs provided that the
purchaser verifies the validity of the C of C.
Paragraph 10.2.f of ANSI N45.2.13 states: "Means should be provided
to verify the validity of supplier certificates and the effectiveness
of the certification system, such as during the performance of
audits of the supplier or independent inspection or test of the
items."
Curing the August,1985 inspection, PGE's position was that since
they were purchasing off-the-shelf catalog items, i.e., commercial
grade under 10 CFR 21, the quality requirements of Appendix B to 10
CFR 50 were not applicable. They stated that the detailed review of
the original environmental qualification test report for the component,
and the receipt and post installation testing performed on the components
by PGE verified the validity of the C of C.
The inspectors' position was that since PGE had specified the
requirements of IEEE-323 and/or IEEE 344 (specifications unique
to the nuclear industry) in the purchase orders for the ten
components, the components did not meet all the tests for commercial
grade under 10 CFR 21. The quality requirements of 10 CFR 50,
Appendix B, therefore, are applicable, and the applicable requirements
should have been imposed. In reviewing PGE's receipt and post
installation test requirements, the inspectors determined that the
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testing would not verify that the components would meet the
requirements of IEEE-323 or 344, since the tests were conducted in
a normal environment, (i.e., ambient temperature, humidity and seismic
conditions) rather than under the conditions required to satisfy
Trojan's seismic response spectra or environmental qualification
requirements.
Therefore, with no evidence to show that the manufacturer had
maintained the qualified configuration for the component or that PGE
had verified the validity of the C of C, PGE was found to be in
noncompliance with Appendix B, and their FSAR commitments.
b. Followup Inspection
Based on PGE's response to Inspection Report 85-025, a followup
inspection at PGE was conducted on October 30-31, 1985. PGE's
response, dated October 14, 1985, stated that a number of the
components listed as safety-related in Table 1 of Inspection Report
85-025, were, in fact, not safety-related. In addition, PGE modified
their position that no quality requirements were necessary for 0A
Code D items on which the additional requirements of IEEE-323 and
344 had been imposed. Their response stated that IEEE-323 and 344,
themselves, imposed the applicable QA requirements and therefore,
imposition of Appendix B was not necessary.
To substantiate their position, PGE showed the inspectors their
equipment "Q-List", i.e., those pieces of equipment considered
safety-related. PGE noted that the two pieces of equipment
highlighted in Paragraph 3.c of inspection report 85-025 (an RCS
pressure recorder and a square root extractor for the AFW system)
were not listed in the equipment "Q-List" and were therefore not
safety-related. In later discussions between the inspectors and
personnel in the Instrumentation and Control Systems Branch of the
Office of Nuclear Reactor Regulation, it was determined that the RCS
pressure recorder is safety-related and should have been listed in
the' equipment "Q-List".
The purchase order for the RCS pressure recorder was issued to
Branom Instruments and specified a pressure recorder manufactured by
Texas Instruments (TI). Neither company had been audited or appeared
on PGE's Evaluated Contractor and Supplier List (ECSL). The purchase ,
orders from PGE to Branom and from Branom to TI imposed IEEE-344-1975 ;
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and required a Certificate of Conformance attesting to the fact that
the specification had been met, but no additional quality requirements
were imposed. As previously stated in paragraph 3.a, PGE's QA
program and FSAR commitments required them to verify the validity of l
the C of C through audits of the supplier or independent inspection
or test of the items. PGE had not performed an audit at Texas
Instruments and Mark Cooksey, the Electrical Engineering Section
Supervisor, stated that the testing performed by PGE did not, nor was
it intended to, verify the ability of the equipment to function
during or after a seismic event. Since PGE did not adequately
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.- verify the validity of the RCS pressure recorder through testing or
inspection,-and the manufr.cturer did not have a quality program
' meeting the applicable portions of Appendix B (see Inspection Report
99901028/85-01), the potential violation of the requirements of 10
CFR 50 Appendix B identified in Inspection Report 85-025 is
considered valid.
.In preparing this report, the inspectors again reviewed PGE's
position on imposing Appendix B requirements to supplement those
contained in IEEE-323 and IEEE-344. A thorough review of IEEE-344
- was performed and it was concluded that IEEE-344 contained no
-quality assurance requirements. A thorough review of IEEE-323 was
- also performed, particularly the first paragraph of Section 4,
" Introduction", which is the reference PGE based their position on.
- The first paragraph states
"The manufacturers and users of Class 1E equipment are required to
provide assurance that such equipment will meet or exceed its
t performance requirements throughout its installed life. This is
, , accompl_ished through a disciplined program of quality assurance that
includes but is not limited to design, qualification, production,
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quality control, installation, maintenance, and periodic testing.
This document will treat only the qualification portion of the program."
The last sentence of the paragraph quoted above clearly states that
IEEE-323 does not impose any of the other elements listed. The other
elements listed are only intended to provide guidance to the purchaser
as to what is necessary in the way of controls. Therefore, PGE's
procurement procedures were inadequate in that they failed to impose
the applicable portions of Appendix B when IEEE-323 and IEEE-344 had
been imposed or to separately qualify each item purchased.
Drafts of five new Nuclear Division Procedures designed to strengthen
PGE's procurement program were reviewed and appeared adequate. The
inspectors also reviewed the list of vendors which PGE had used recently
but was not able to place on their ECSL by means allowed under their
QA program. It was determined that four of the vendors provided
safety-related services (three calibration services vendors and one
nondestructive examination service vendor). PGE was in the process of
scheduling audits at these vendors at the time of the inspection.
4. - Potential Violation 344-85-025-02 (Part 21)
The inspe'ctors reviewed PGE's revised Part 21 procedure and determined that
it was adequate. However, the position on the appl.icability of 10 CFR 21
as stated in the PGE response to Inspection Report-50-344/85-025 is
incorrect. Because PGE imposed IEEE-344 and IEEE-323 in 'the purchase order
for the circuit breakers, all three conditions stated in paragraph 21.3(a)
(4)(a-1) for determiling commercial grade have not been met. According
to paragraph (a-1)(1), if an item is subject to design or specification
requirements unique to facilities licensed pursuant Part 50, the item is
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not commercial grade. IEEE-323 and IEEE-344 are specifications unique to
facilities licensed under Part 50. They are titled " Qualifying Class IE
Equipment for Nuclear Power Generating Stations" and "IEEE Recommended
Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power
Generating Stations." As such, PGE's procurement procedures fail to assure
that Part 21 is imposed when specifications unique to facilities licensed
under Part 50 are imposed.
5. Unresolved Item 344-85-025-03 (Nonconforming Material)
PGE's response appears adequate, however, the revised procedures had
not been completed at the time of the inspection. This item remains
unresolved.
6. Unresolved Item 344-85-025-04 (Terry Turbine)
PGE's response indicated that the proper fasteners and alignment pins
have been installed. However, the response does not address the issue of
whether the turbine configuration as found met the seismic qualification
requirements for Trojan. This item remains unresolved.
7. Unresolved Items 344-85-025-05 and 06 (Incomplete Test Data) *
The inspectors reviewed a report of an audit performed by PGE of the
adequacy of testing and test documentation. The audit covered the-areas
noted in Inspection Report 85-025 as having incomplete documentation of
test results. The audit team was able to locate all the test documentation,
with some difficulty, and ascertain that all necessary testing was performed.
However, the QA Manager informed the inspectors that changes were being
made to procedures to assure that this type of documentation will be more
easily retrievable in the future.
These items are considered closed.
8. EXIT MEETING
The insp'ectors met with Mr. A. Olmstead on October 30 and 31, 1985, to
summarize the scope and findings of the inspection.
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