ML20210F424
| 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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FEB 4
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
(cc cont'd. next page)
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8702110066 870204
ADOCK 05000382
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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
bcc to DMB (IE01)
bec distrib. by RIV:
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RPB
D. Weiss, RM/ALF
RRI
R. D.' Martin, RA
SectionChief(RPB/C)
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MIS System
Project Inspector
RSTS Operator
R. Hall
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[ POWER & L1GH TLO U I S I A N A / ai7 84RoNNe sTR
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NEW ORLEANS, LOUISIANA 70160
(504)595 3100
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January 26, 1987
A4.05
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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Page 3 of 13
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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
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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Ptg2 10 of 13
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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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