IR 05000275/1985016
| ML17083B592 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/07/1985 |
| From: | Crowley T, Dodds R, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17083B591 | List: |
| References | |
| 50-275-85-16, 50-323-85-16, NUDOCS 8505300499 | |
| Download: ML17083B592 (16) | |
Text
U.
S.
NUCLEAR REGULATORY COR1ISSION
REGION V
Report Nos. 50-275/85-16 and 50-323/85-16 Docket Nos.
50-275 and 50-323 License No.
DPR-76 Construction Permit No.
CPPR-69 Licensee:
Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Facility Name:
Diablo Canyon Units 1 and
Inspection at:
Diablo Canyon Site, San Luis Obispo County, California Approved by Inspection co d'ucted Harsh 25 through April 26, 1985 Inspectors:
d,t, B. Pereira, Reactor Inspector T. Crowley, Reactor ns ector R. T. Dodds, Chief, Reactor Projects Section
/~ au 1f5 Da e
igned I'
Da e
igned
Dat igned
~Summa u Ins ection from tiarch 25 throu h A ril 26 1985 (Re ort Nos. 50-275/85-16 and 50-323/85-16)
involved 86 inspection hours by two inspectors.
Results:
No violations or deviations were identified.
8505300499 850508 PDR ADOCK 05000275
DETAILS Persons Contacted M. Tresler, Project Engineer Assistant, PGSZ S.
M. Skidmore, Manager, Quality Assurance, PGRE D. Aaron, Quality Assurance Engineer, PGGE P.
G. Dahan, Quality Control Engineer, PGGE J. Brattois, Special Projects, PGSE R. Hobgood, Supervisor, Quality Control, PG&E K. A. Nilson, Field Engineer, PGSZ H. Karner, Manager, Quality Assurance/Quality Control, Pullman Power Products NOTE:
The allegation characterization statements contained in this report are a paraphrasing of the staff's understanding of the allegers concern based upon copies of their affidavits and other documents submitted by allegers.
The characterization statements do not represent a staff assessment, conclusion or position.
Alle ation or Concern Nos.
1664 1668 1673 1674 1675 1676 and 1677 ATS:
RV-85A-0999 Characterization Pullman Power Products'iscrepancy Report j/9173 (12-21-84)
does not provide for a system of identification, documentation, segregation and disposition of Cardinal materials previously purchased and installed by Pullman in both units of the Diablo Canyon Nuclear Plant.
This is a
nonconformance to
CFR 50 Appendix B criteria XV - Nonconforming Materials, Parts or Components and Criteria XVI - Corrective Action.
Pullman DR//9173 only provides for a system of identification and documentation for material in Pullman's warehouse/storage areas which were manufactured by Cardinal.
PGSE does not provide a system of identification, documentation and segregation of Cardinal materials previously purchased and installed by Pullman in the plant.
Nonconformance to
CFR 50, Appendix B, Criteria XV and XVI.
PGSE QA instructions do not specifically provide for a system of identification, documentation and segregation of all Cardinal materials previously purchased and installed by Pullman in the plant.
Nonconformance to
CFR 50, Appendix B,.Crit'eria XV and XVI.
Failure by PGSE/Pullman's DRj/9173 to address/identify, document and segregate Cardinal materials previously purchased and installed by Pullman in the plant is a significant condition adverse to qualit Cardinal materials'uality is indeterminate for material purchased prior to 1-9-84.
PGSE conveniently ignored findings on Cardinal's (}A program until well after any licensing impact.
Im lied Si nificance to Desi n
Construction or 0 eration Pullman has purchased and installed Cardinal bolts and fasteners at the Diablo Canyon Nuclear Plant since 1977.
Since Cardinal's past equality Assurance Program has been identified by the NRC and PGRE to have significant deficiencies making the quality of their material indeterminate, this material could result in an inability of safety systems to perform their intended safety functions.
Assessment of Safet Si nificance
~Back round On June 29, 1984, the NRC issued Information Notice No. 84-52,
"Inadequate Material Procurement Controls on the Part of Licensees and Vendors" to inform licensees of deficient procurement controls and quality assurance (gA) practices on the part of suppliers of nuclear materials and to call attention to possible generic problems in procurement activities of licensees.
The Information Notice stated that a large number of quality-related deficiencies on the part of nuclear suppliers was revealed in the NRC inspections.
One of these nuclear suppliers, Cardinal Industrial Products Corp.,
was suspected of deficient procurement controls and t}A practices.
As a result, PG&E conducted an audit of Cardinal Industrial Products on December 6-7, 1984 and January 3-4, 1985, in Las Vegas, Nevada.
The purpose of the audit was to determine if they had adequately implemented their quality assurance program for materials Cardinal supplied to the Diablo Canyon Power Plant.
The audit found that there was insufficient documented evidence to support the adequate implementation of Cardinal'
quality assurance program.
Cardinal was removed from the PGSkE t}ualified Supplier's List on September 28, 1984, after PGRE's review of the NRC inspection of Cardinal.
Per PGScE's request, Pullman Power Products issued Discrepancy Report (DR)
//9173 on December 21, 1984 which placed all material in Pullman's warehouse which was manufactured by Cardinal Industrial Products Corporation wn hold.
This DR disposition included listing all Cardinal manufactured items currently in stock, identifying all items currently ordered from Cardinal but not yet received, segregating and retaining a
minimum of four items of each size and heat number for possible future testing, and issuing instructions for conditionally releasing items placed on hold pursuant to PGSE's authorization in their letter to Pullman dated December 21, 1984.
This action was approved by the Technical Review Group (TRG) on January 21, 1985 in accordance with section 10.1 of the PGRE (}uality Assurance Progra The alleger has stated that the Pullman Power Products DR//9173 does not provide for a system of identification, documentation, segregation and disposition of Cardinal materials previously purchased and installed by Pullman in both units of the Diablo Canyon Nuclear Plant, and is applicable only for material manufactured by Cardinal.
The alleger has stated that PGSZ and PGSE equality Assurance. instructions do not specifically provide for a system of identification, documentation and segregation of Cardinal materials previously purchased and installed by Pullman in the plant.
According to the alleger, this is a nonconformance to
CFR 50, Appendix B, Criteria XV and XVI.
In addition, the alleger states that failure by PGSE/Pullman DR/j9173 to address/identify, document and segregate Cardinal materials previously purchased and installed by Pullman in the plant is a significant condition adverse to quality.
The alleger states that Cardinal materials'uality is indeterminate for material purchased prior to 1-9-84.
Staff Findin s
The problem area in question and selected records of PGRE and Pullman Power Products were examined and assessed by the inspectors.
The inspectors examined these allegations with the intent of evaluating whether licensee management had acted in a responsible manner in their assessments and conclusions, and determining whether any technical question remains unresolved.
Cardinal Industrial products has developed and is currently implementing an extensive action plan for revalidation of materials supplied to the nuclear industry that has been reviewed and approved by the NRC's Vendor Program Branch.
The approved program includes documentation/
certification verification, physical and chemical analysis verification tests of selected lots of material, and an extensive vendor validation and monitoring program to ensure purchase order requirements have been passed down through the channel to the subcontractor(s).
The sampling plan basis will provide a 95/ confidence level for each product category supplied through each "channel" (i.e. includes all contractors down to the raw material producer).
The licensee has determined that they and their contractors, principally Pullman, have received 197 purchase orders consisting of 943 line items from Cardinal.
Attached to this report is PGScE letter No. DCL-85-153 which is a status report of the Cardinal revalidation program as it applies to Diablo Canyon.
Any identified discrepancies resulting from the revalidation program are being dealt with (located and segregated as appropriate)
in accordance with the licensee's gA program for
"Nonconformances and Corrective Actions," Procedure 10.1.
The ASHE SA material c'ertification review program has been completed.
The certification review for other than ASHE material was 90% complete.
The results of the reviews to date have disclosed that appropriate documentation is in place for materials reviewed with one exception pertaining to forty-eight A193 studs and A194 nuts supplied to Unit 2 for the main steam line isolation valves.
In this case, material traceability was lost on the studs during the forming process, and the nuts had been purchased from an unapproved sourc The inspector verified that the discrepant studs and nuts had been located and replaced with acceptable material in accordance with the gA program.
The licensee has tested these studs and nuts and determined that they meet the required material specifications and, therefore, would have performed as designed had not the discrepancy been identified.
Staff Position The staff concludes that PGSE has a gA program inplace for controlling nonconforming material and that this program was followed in the identification and segregation of material in stock and in the dispositioning of the one instance where the NRC approved Cardinal revalidation program identified potential discrepant material.
This series of allegations is considered closed.
Action Re uired None.
Alle ation or Concern Nos.
1666 1665 and 1667 ATS:
RV-85A-0999 Characterization Pullman Power Products'endor equality system audit of Cardinal did not address heat treating of material as required.
Pullman's Vendor equality system audit program for Cardinal is in nonconformance to AS51E Section III, NCA-3820, a, b, and c (1980 Edition)
and
CFR 50 Appendix B Criteria VII - Control of Purchased hlaterial, Equipment, and Services.
Cardinal appears to have had no quality system program covering heat treating of material during 1981.
Im lied Si nificance to Plant Desi n
Construction or 0 eration Incorrect or nonexistant heat treatment of Cardinal material purchased for Diablo Canyon Nuclear Plant may result in the quality of the material to be indeterminate, thus resulting in an inability of safety systems to perform their intended safety functions.
Assessment of Safet Si nificance The alleger has stated that Pullman Power Products'endor quality system audit of Cardinal did not address heat treating of materials.
Specifically, checklist item //18 - verify if heat treating is performed in accordance with approved procedures
- is marked not applicable and no audit was performed.
Checklist items jj19, //20,
//21 and j/29c having similar heat treatment requirements were also marked not applicable and no audit was performed.
The alleger has stated that Pullman's Vendor
Quality System Audit program for Cardinal is in nonconformance to ASME Section III, NCA-3820 a, b, and c (1980 Edition) and
CFR 50 Appendix B
Criteria VII,.since Pullman did not audit the heat treatment of fasteners manufactured and/or supplied by Cardinal.
The alleger has stated that this is a significant condition adverse to quality.
The alleger has stated that Cardinal appears to have had no Quality System Program covering heating treating of material during this time period.
Staff Findin s
The subject of heat treating was examined and assessed by the inspectors.
The subject was also discussed with licensee personnel'he inspectors verified that Cardinal did not perform heat treating of materials, but rather had Precision Heat Treating Company perform the heat treatment before 1981.
As a consequence there was no Cardinal Heat treatment program and the audit checklist items //18, jj19, j/20, /f21, and jj29c were correct in being marked not applicable.
The first time Cardinal performed in house heat treatment for Diablo Canyon material was February 21, 1983.
There was no prior in house heat treatment used on Diablo Canyon or Pullman materials.
Therefore, heat treating records for Pullman orders were, in fact, not auditable at the Cardinal facility.
The alleger's interpretation is incorrect concerning Pullman's Vendor Quality System Audit program for Cardinal per ASME Section III, NCA-3820 a, b, and c and
CFR 50 Appendix B Criteria VII, since Pullman conducted audits of Cardinal's Quality Assurance program.
Cardinal conducted a system of planned and documented external audits performed to verify compliance with all aspects of the suppliers and suppliers of subcontracted services (such as heat treatment).
Cardinal conducted Q.A.
surveys of Precision Heat Treating on 8/25/78, 8/27/79, 7/3/81, 12/6/82, and 12/1/83 by C.W. Eliason.
All audits and surveys by Cardinal found Precision Heat Treating acceptable.
Pullman's audit revealed that Cardinal's Quality Assurance llanual, Section 8 performs audits of extern'al suppliers of subcontracted services.
Even through Cardinal had no heat treatment program,"
the Cardinal audits of Precision Heat Treating verified that the material was properly prepared and had quality documentation for shipment to Pullman.
Therefore, there is no deficiency in the 1980 and 1981 audits of Cardinal with respect to heat treating and no non-conformance to AStK Section III NCA or
CFR 50, Appendix B."
Staff Position The staff concludes that this allegation is not valid based on both Pullman's aad Cardinal's audits.
There is no requirement for Pullman to conduct an audit of Precision Heat Treating.
Cardinal's prior audits of their heat treatment supplier indicated satisfactory results and no trend towards poorer quality was indicated.
These allegations are closed.
No violations or deviations were identified.
None Alle ation or Concern Nos.
1669 1670 1671 and 1672
ATS:
RV-85A-0999 Characterization Pullman's Vendor t}uality System Audit did not list and no audit was performed to determine if the person or department responsible
.for defining and implementing the overall effectiveness of the quality program reported regularly on the effectiveness of the program.
Pullman's Vendor (}uality System Audit failed to check Cardinal employees who performed functions within the scope of ASt1E Section III to determine if they were qualified to perform their duties in 1981.
Pullman's 1981 audit of Cardinal did not audit to see if nondestructive examinations (NDE) were performed in accordance with approved procedures.
Pullman's 1981 audit of Cardinal did not audit major portions of the quality system program, as required.
Im lied Si nificance to Plant Desi n
Construction or 0 eration The overall effectiveness of the quality assurance program needs to be reported to ensure material, procedural, and operational requirements are met on a continuing basis.
Only qualified Cardinal employees who perform functions within the scope of ASME,Section III should perform those functions.
NDEs need to be performed in accordance with approved procedures.
Assessment of Safet Si nificance
~Back connd The alleger has stated that Pullman's audit did not list or determine the person or department responsible for defining and implementing the overall effectiveness of the program.
The alleger further states the Pullman audit failed to check Cardinal employees who performed functions within the scope of ASME Section III to determine if they were qualified to perform such duties.
Pullman's audit failed to determine if NDE's were performed in accordance with approved procedures.
In addition, Pullman's audit of Cardinal did not audit major portions of the quality system program, as required.
The inspectors examined the 1981 Pullman's audit of Cardinal and assessed
'the alleger's findings of Pullman's audit deficiencies.
The inspectors verified that Pullman's audit did determine that Cardinal's (}uality Assurance Hanual, Section 3 had the necessary items implemented to define and implement the overall effectiveness of the gA program.
The items listed were that the person was designated in writing, independent from production pressures, and had direct access to managemen The audit finding code was satisfactory.
Cardinal's equality Assurance Manual, Section 3 satisfied the audit evaluation step.
The staff disagrees with the alleger, since Cardinal's gA manual, section 3 listed the person or department responsible for defining and implementing the overall effectiveness of the program.
Pullman's audit did list the individuals or department, but only quoted Section 3 of the (}.A. Manual.
The alleger is correct in his statement that no Cardinal employee who performed functions within the scope of ASME Section III were audited to determine if they were qualified as specified by Section III.
However, no Cardinal personnel performed NDE, and no special processes were performed by Cardinal.
The audit by Pullman clearly states that NDE is performed by Eagle Intermountain Testing and Eagle Intermountain personnel are listed.
Pullman's 1981 audit of Cardinal was correct in not auditing to see if NDEs were performed in accordance with approved prcoedures.
Cardinal has a equality Assurance manual, Section 8 which verifies that subcontractors (Eagle Intermountain Testing)
have gA programs.
The staff found that the Pullman 1981 audit was quite detailed and involved every major activity that Cardinal performed.
It simply did not audit those items that Cardinal did not perform but that had to be subcontracted, such as heat treating and NDE.
Staff Position The staff concludes that the allegations are not valid based on both Pullman's and Cardinal's audit findings.
Pullman's 1981 audit was extensive and examined every activity that Cardinal performed.
Pullman did not audit the subcontractor that Cardinal was using for heat treatment and NDE.
These allegations are closed.
No violations or deviations were identified.
None.