IR 05000244/1996201
| ML17264A394 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/01/1996 |
| From: | Cwalina G, Gautam A, Mary Johnson NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17264A393 | List: |
| References | |
| 50-244-96-201, NUDOCS 9603060449 | |
| Download: ML17264A394 (13) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF TECHNICAL SUPPORT REPORT NO.:
ORGANIZATION:
ORGANIZATIONAL CONTACT:
INSPECTION DATES:
50-244/96-201 Rochester Gas
& Electric Corporation (RG&E)
89 East Avenue Rochester, NY 14649 Dr. Robert C. Mecredy Vice President - Nuclear Operations January 22 through 26, 1996 LEAD INSPECTOR:
OTHER INSPECTORS:
Anil S.
Gautam Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation (NRR)
Joseph J. Petrosino, NRR Date REVIEWED BY:
Gregor Cwal ina, Secti on Chi ef Vendor I spection Section Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation Date APPROVED BY:
Michael R. Johnson cting Chief Special Inspection anch Division of Inspect on and Support Programs Office of Nuclear Reactor Regulation ate 9603060449 96030i PDR ADQCK 05000244
PDR Enclosure
I
1.0 INTRODUCTION A vendor oversight program is a licensee's process for monitoring the vendors'uality control, consistent with the importance, complexity, and quantity of the purchased products or services.
Evaluation of the process falls, in part, under
CFR Part 50, Appendix B, Criterion VII, "Control of Purchased Material, Equipment, and Services,"
which requires licensees to establish specific measures to assure that purchased material equipment and services conform to the procurement documents; and under Regulatory Guide 1. 144,
"Auditing of guality Assurance Programs for Nuclear Power Plants,"
which sets forth NRC requirements for auditing quality assurance programs.
A special inspection to assess the adequacy and effectiveness of RG&E's vendor oversight program for monitoring the vendors'uality control for safety-related equipment was conducted by staff from the Special Inspection Branch of the Office of Nuclear Reactor Regulation, from January 22 through 26, 1996.
f Details of the licensee's vendor oversight program are provided in Section 2.0.
The personnel attending the entrance and exit meetings are listed in Appendix A.
2.0 MONITORING OF VENDORS In general, RG&E had implemented an effective vendor oversight program'o monitor vendor's quality control for safety-related products.
The inspection focused on assessing RG&E's monitoring of nine vendors supplying safety-related products to Ginna.
Vendor oversight program attributes examined included gA organization for monitoring vendors; qualification, audits and surveillance (hereafter referred to as audits) of Appendix B vendors; evaluation of audit findings and feedback of corrective actions to appropriate staff; maintenance of a qualified suppliers list; and qualification and training of appropriate staff.
gA documents and procedures were reviewed in the following areas:
control of purchased material, equipment and services; quality review of procurement documents; evaluation and control of vendor performance; reporting 'and followup of audits results; tracking of abnormal conditions during procurement; and qualification and certification of personnel performing audits.
2.1 Vendor Oversight Program In general, an effective vendor oversight program was implemented.
The inspectors assessed the, attributes and implementation of the vendor oversight program run by a gA manager and 10 procurement gA representatives.
The manager reported to the department manager of Nuclear Assessment, who reported to the Vice President of Nuclear Operations.
The gA manager had the authority to conduct appropriate vendor audits.
gA evaluated vendors in accordance with RG&E procedures, industry information and audits pertinent to the vendor.
Vendors'se of outside organizations was typically identified in the vendor's proposal or bid and assessed by RG&E as
I k'
T n
l,
part of the vendors'ontrol of procurement activities.
RG&E's quality
'control (gC) procedures provided guidance on detecting fraudulent material during receipt inspection and testing.
RG&E Nuclear Assurance issued purchase orders (POs) to vendors from the Ginna site.
The guality Procurement Coordinator performed the quality function for safety related POs.
Procurement documents included, as applicable, the scope of work or material description, technical and quality requirements, gA program requirements, right of access to vendor and subtier vendor facilities, and requirements for documenting, reporting, and dispositioning nonconforming conditions and
CFR Part 21 deviations.
The licensee stated that gA engineers typically did not review POs but received and reviewed copies of those POs which imposed source audits on the vendor (e.g., if a restriction was placed on a vendor).
gA staff ensured that qualification and annual, triennial, and other interim audits, were performed by RG&E or outside organizations to monitor vendors supplying Appendix B products and services.
gA audits were performed in accordance with written procedures and checklists.
Audits included monitoring, witnessing and observing activities, such as inspections, examinations, and performance tests.
The licensee stated that procedure A-1404, Section 3.5. I addressed distribution of industry events reports on an information-only basis by the Operating Experience department (Nuclear Operations)
to affected departments.
"Licensee Contractor and Vendor Inspection Status Report,"
was routed through the procurement gA group.
The inspectors questioned why NRC Information Notice 88-81, "Failure of Amp Window Indent Kynar Splices and Thomas and Betts Nylon Wire Caps during Environmental gualification Testing,"
was not reviewed by gA procurement engineers when qualifying Amp (Appendix B
vendor).
The licensee stated that the notice was reviewed by its electrical engineering staff in 1988 but not forwarded to gA because no changes to the design basis for 10 CFR 50.49 environmentally qualified electrical equipment were applicable.
The licensee determined that NRC information notices and bulletins pertinent to gA evaluations of vendors were currently received by procurement gA engineers and agreed to review this area to determine if enhancements were needed.
gA tracked defects in materials identified at the vendor facility through the vendor's corrective action process.
For significant programmatic deficiencies, restrictions were imposed on the vendor or stop-work orders issued.
Restrictions on a vendor were noted by gA on the qualified suppliers list and updated every month or as changes occurred.
Nonconformances for which the vendor had recommended a disposition of "use-as-is" or "repair" at the vendor's facility were normally reviewed and dispositioned by the RG&E procuring organization.
The inspectors had no concerns in this area.
2.2 Evaluation of Appendix B Vendors The inspectors assessed RG&E's qualification and monitoring of nine vendors supplying safety-related products to Ginna.
The vendors included Hodumend (refurbished power supplies),
Amp Products Inc. (terminals and splices),
Fisher Service Company (valve parts),
Amerace Electronic Components (Agastat relays),
Reliance (electric motors),
Rosemount Nuclear Instruments (pressure and temperature devices),
Babcock 5 Wilcox Canada (steam generators),
Automatic Switch Company (solenoid operated valves),
and Limitorque Corporation (valve operators).
The vendors were selected based on the safety significance of their products and the history of product deficiencies or failures.
Histories were obtained from electrical and instrumentation corrective maintenance work orders, reports of nuclear assessment activities regarding component failures, vendor restrictions noted in the gSL, licensee action reports of abnormal conditions and events, nuclear plant reliability data system equipment failure reports,
CFR Part 21 reports, licensee event reports, and NRC inspection reports and information notices.
The NRC inspectors reviewed documentation on the qualification and evaluation of the nine selected vendors, including RG&E's performance-based annual and triennial quality audits of vendors; RGRE's followup of audit findings and corrective actions; and its feedback of appropriate findings and corrective actions to management and procurement staff.
Documents indicated that qualification, annual audits, triennial audits were performed on time; audit findings wer e evaluated; and feedback provided to appropriate staff, including Nuclear Assurance (site),
gC, purchasing, procurement, and engineering document control.
RG8E's qualification and performance evaluation of 'Appendix B vendors considered the vendor's design and manufacturing capabilities; the gA program and its capability to provide the required items or services; audits of the vendor's gA program status and performance history; and maintenance of vendor data on the qualified suppliers list (gSL).
Initial qualification and annual and triennial audits for qualifying and monitoring the nine selected Appendix 8 vendors were primarily conducted by outside organizations, including the Nuclear Procurement Issues Committee (NUPIC) and utilities.
The NUPIC sent questionnaires to pertinent licensees to determine areas the licensees preferred inspected, and communicated its audit results to the licensees.
The annual vendor evaluation required vendors to identify any changes to products, services, facilities, personnel or quality involvement which could impact qualifications.
POs required vendors to identify and disposition all nonconforming conditions in accordance with the vendor's quality requirements.
Nonconformances to the technical and quality requirements of the POs dispositioned as
"use as is" or "repair" were required to be submitted to the licensee.
gA expected vendors to identify any problems; however, audit evaluation checklists did not require procurement gA engineers to actually question a vendor whether any deficiency or nonconformance had been identified pertinent to products in process at vendor facilities.
The licensee agreed to review this area to determine if enhancements were needed.
Use of outside organizations for auditing vendors was based on
CFR Part 50, Appendix B, and Regulatory Guide 1. 144, which allow use of outside organizations to reduce the number of external audits as an alternative method for qualifying and monitoring vendors as long as all pertinent information is adequately evaluated.
For example, the initial and ongoing qualification and performance evaluation of Amp Products, Inc.
(Amp), were completely based on audits performed by NUPIC and other organizations, and evaluated by RGLE's gA.
Amp supplied electrical terminals and splices for safety-related applications at the Ginna station and was qualified by gA in 1985 to 10 CFR 50 Appendix
requirements.
The last gA annual review was performed on August 10, 1993, and the last performance audit was performed by NUPIC on June 9,
1995.
gA's annual review had noted that Amp had made a revision to its gA manual but not provided it to RG&E.
gA requested the vendor to provide the manual for review.
Pertinent audit results were provided to appropriate staff.
The licensee provided evidence that its electrical engineering staff had evaluated Amp splice failures and that no restrictions were placed on the vendor because RG&E decided to install Raychem splices on the Amp nylon splices installed in harsh environments (RG&E EEg-I Form Package 39).
All purchase orders to Amp were completed and closed.
The basis for qualification of the selected vendors, including those performed by outside organizations, appeared to be adequate and appropriately documented.
However, one concern was identified regarding RG&E's assessment of the vendor Modumend.
Modumend was audited on. November 2, 1993, by RG8E procurement gA to determine if the vendor could be placed on the RG&E gSL.
The procurement gA team leader identified one finding, that the vendor had not conducted internal audits (required by Appendix 8 Criterion XVIII). During this time (1993-1994),
the guality Performance Department Manager (currently reassigned)
and gA Manager (retired)
encouraged their staff to generate revenue for RG&E.
With the gA manager's approval, the gA team leader approached Modumend and suggested RG&E be hired as an independent contractor to perform the internal audit that RGSE had earlier found not to have been done.
The vendor agreed but RG&E later decided not to perform the audit.
However, with his immediate manager's approval, in June 1994, the gA team leader did the internal audit for the vendor for a fee, independently of RG&E.
The gA team leader (with the Modumend vice president as a team member)
closed the RG&E's earlier finding and identified no new findings.
As a result, RG&E's gA team leader performed Modumend's quality function, instead of assessing Modumend's performance of the function.
The inspectors noted that RG&E's policy statement,
"Principles of Business Conduct," dated September 1992, issued by the Chairman, President and Chief Executive Officer of RG&E, stated that without the specific written approval of the Chairman of the Board, no employee should serve as a director, officer, consultant or employee of any business organization which was a competitor or supplier of RG&E where there was the risk or appearance that preferential treatment may be given or received.
Encouraging gA engineers to raise revenues from and serve as a consultant of Modumend appears to be in conflict with this policy.
The licensee stated that current management would avoid any perception of a conflict of inter est with a vendor and would not suggest to their engineers to perform such an audit.
During the NRC inspection, the licensee instructed gA engineers not to perform work for a company that gA was responsible to assess, either as independent consultants or as RG&E employees.
The inspectors had no further concerns in this are I E
2.3 Qualified Suppliers List QA maintained the QSL on an electronic database and was responsible for making changes to existing vendor information.
The QSL included vendor contact information, details of vendor capability, dates of vendor qualification, and any vendor restrictions (e.g.,
RG&E quality checks to be performed during manufacture and/or prior to shipment).
The inspectors determined that pertinent information for the nine selected vendors was maintained on the QSL.
QA used a password to restrict access to the QSL database and protect it from inappropriate changes or deletions (e.g.,
removal of vendor restrictions).
The accounts payable staff could only access the data base to enter information about new vendors.
Other RG&E groups had "read only" access.
The inspectors had no concerns in this area.
2.4 Training and Self-Assessment Qualification records indicated that individuals assigned to perform procurement activities were properly trained and qualified.
Qualification records documented the knowledge and training of procurement QA engineers, including their performance of quality activities (e.g., assisting in audits)
before their qualification as auditors or lead auditors.
Records indicated satisfactory completion of an oral examination on the QA program and procedures, NRC regulations, regulatory guides, NUPIC and Electric Power Research Institute (EPRI) guidelines, and industry standards; attendance of appropriate training classes; and completion of required reading on qualifying and auditing vendors.
The procurement QA engineers were certified as audit team leaders to American National Standard Institute (ANSI) N45.2.23, and as quality system Lead Assessors to the American Registration Assessment Board of the International Organization for Standardization (ISO) 9000.
The inspectors had no concerns in this area.
The last independent assessment of RG&E's QA program, including its vendor oversight program, was performed on December 22, 1994.
An October 16, 1995, internal assessment was performed by a technical specialist from EPRI and other RG&E team members.
The internal assessment team concluded that RG&E's overall procurement engineering program was technically sound and significantly better than at most nuclear facilities reviewed.
However, the assessment noted road blocks in two-way communication between procurement engineering and QA procurement.
The assessment recommended refresher training for staff and managers.
The licensee stated that actions in response to a
self-assessment of the procurement process were planned with a completion date of July 1996, and that QA would assess if any remedial training was necessary to correct the lack of communication identified by the independent audit.
The inspectors had no concerns in this area.
3.0 EXIT INTERVIEW I
The inspectors conducted an exit meeting on January 26, 1996 at the RG&E corporate office in Rochester, New York, to discuss the major areas reviewed during the inspection.
Licensee representatives who attended this meeting are identified with an asterisk in Appendix B of this report.
The licensee did not identify any documents or processes as proprietar '%
APPENDIX A Persons Contacted at Entrance and Exit Meetings Rochester Gas 5 Electric Richard J. Watts Michael P. Lilley Mark Shaw George Wrobel Raymond M. Bozarth Paul,Hutner Gregory R.
Amsden Al Pitts Jon Bergstrom Michelle L. Preik Terry Kirkpatrick Manager Nuclear Assessment Manager equality Assurance Manager Materials and Procurement Manager NS8L SA Team Leader gA Engineer gA Engineer gA Engineer gA Engineer gA Engineer equality Procurement Coordinator Nuclear Re ulator Commission Anil S.
Gautam JosepH J. Petrosino Peter D. Drysdale tt Team Leader, NRR Reactor Inspector, NRR Senior Resident Inspector, Ginna Denotes those attending the exit interview on January 26, 1996, at the conclusion of the inspection
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