IR 05000275/1989022
| ML16342B620 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/17/1989 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16341F425 | List: |
| References | |
| NUDOCS 8912040087 | |
| Download: ML16342B620 (10) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8912040087 DOC.DATE: 89/11/17 NOTARIZED: NO FACIL:50-275 Diablo Canyon" Nuclear Power Plant, Unit 1, Pacific Ga 50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga AUTH.NAME AUTHOR AFFILIATION ZIMMERMAN,R.P.
Region 5, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION SHIFFER,J.D.
Pacific Gas
& Electric Co.-
SUBJECT:
Forwards Insp Repts 50-275/89-22
& 50-323/89-22 on 890821-1016.Deficiencies noted.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES DOCKET 05000275 05000323 INTERNAL:
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LTTR '6 ENCL
I<OY I 7 198S Docket No. 50-275 and 323 Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Attention:
Mr. J.
D. Shiffer, Vice President Nuclear Power Generation Gentlemen:
SUBJECT:
NRC INSPECTION AT PGSE GENERAL OFFICE This refers to the special inspection conducted by Mr. F.
R.
Huey of this office and Messrs.
R.
P. McIntyre and S.
M. Matthews of the Office of Nuclear Reactor Regulation during the period of August 21 through October 16, 1989.
This inspection examined your-activities as authorized by NRC License Nos.
Discussions of our findings were held with members of your staff at the conclusion of the inspection.
Areas examined during this inspection are descr'ibed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel and observations by the inspectors.
This inspection involved a review of actions being taken by PGImtE to resolve recently identified significant deficiencies in their guality Assurance program as it relates to the procurement of safety-related plant equipment.
The specific deficiencies involve numerous inadequate audits of PG8E safety-related equipment suppliers in accordance with the requirements of
CFR Part 50, Appendix B.
The NRC inspection concluded that you had too narrowly limited the scope of your review of inadequate supplier audits to only those performed by your audit contractor, Cygna.
The inspectors noted that similar deficiencies appeared to be applicable to PGIIE performed audits as well.
You agreed with the inspector's corments and committed to expand your investigation and advise the NRC of the results and the need for any additional analysis supporting continued plant operation during October 1989.
The NRC inspection also determined that your root cause assessment of these procurement program deficiencies, although not yet complete, appeared to be adequate.
In this regard, the inspectors noted that a primary cause of the observed problems appeared to involve a serious breakdown of management control and overview within the PGSE Ouality Assurance department and inadequate PGSE management of the supplier audit contract with Cygna, resulting in numerous audits which were inadequate in both scope and content to meet NRC requirements.
Enforcement action associated with these S9120400S7 S01117 PDR ADOCK 05000275 Q
v
7 iong deficiencies will be the subject of separate correspondence, pending completion of the PGSE and NRC investigations.
Your October 2, 1989 letter, DCL-89-255, addresses the concerns raised during the above referenced NRC inspection.
As noted during discussion with members of your staff on October 16, the NRC remains concerned that several aspects of your current corrective actions appear to be unclear or incomplete.
Specific concerns in this regard, which will be reviewed during a subsequent inspection, include the following:
1.
Your letter states that based on the results of your review of inadequately performed PGRE supplier audits and considering other indications of specific supplier quality program deficiencies (e.g.
subsequent reaudit of some suppliers),
a total of 18 suppliers were removed from the PGKE gualified Suppliers List (0SL).
Your letter goes on to state that 17 of these suppliers were subsequently returned to the OSL, based on what appears to be a qualitative review of various generic industry performance history data bases (e.g.
NPRDS, lOCFR21 reports, NRC notices, etc.).
The information provided in your October 2 letter does not support your apparent conclusion that these suppliers are qualified for inclusion on your OSL.
However, the primary issue is not whether PGSE can use historical performance to place suppliers on the (}SL, but what must be done by PGSE to assure that hardware in stores and installed in the plant are suitable for their intended application.
The majority of the historical database is based on performance during normal operation, and does not provide a basis to substantiate that the equipment will perform under all design requirements.
The use of performance history alone does not constitute an adequate dedicati'on, basis, although this approach may be an acceptable basis for continued plant operation.
2.
Your letter states that 84 out of a total of 276 supplier audit reports (involving 205 suppliers)
are inadequate.
In particular, your letter states that 38 reports involved "significant" deficiencies.
Nevertheless, the letter concludes that your "thorough review of the vendor audit program... found it to be generally effective in meeting regulatory commitments and in identifying supplier quality problems".
Your letter does not present evidence to support this conclusion, nor does such a conclusion appear to be warranted.
3.
Your letter states that the Technical Review Group, which evaluated the vendor audit concerns, was chaired by the Ouality Assurance Manager.
The assignment of the gA Manager to this sensitive position, when he appeared to have contributed to the observed deficiencies, appears to jeopar'dize the independence of the review process and may have impacted the thoroughness of the licensee's root cause evaluation.
During our meeting on October 16, members of your staff acknowledged'the above concerns and stated that actions would be taken to address these concerns prior to a followup NRC inspection.
In this regard, during the period of October 23 through November 9, 1989, the NRC conducted a followup inspection of your actions, as described in your October 2 letter.
The results of that inspection will be discussed in a separate inspection report, however, it should be noted that those results bear out the above noted concerns.
In
NOV i 7 l98S particular, the cited historical performance database does not appear to provide a valid basis for accepting material provided by some of the
vendors that were removed by PGSE from the OSL.
During discussions with the inspectors during the week of November 13, 1989, PGSE acknowledged the NRC concern and stated that a more comprehensive review of the -criteria for accepting these vendors as qualified suppliers would be conducted over the next few weeks and the final results would be reported to the NRC in December 1989.
In accordance with 10 CFR 2.790(a),
a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
Should you have any questions concerning this inspection we will be pleased to discuss them with you.
g(,
M( Nl cf))'oy P.
Z overman, Director Division of Reactor Safety and projects Enclosure:
Inspection Report No. 50-275/89-22 and 50-323/89-22 cc w/enclosure:
S.
M. Skidmore, PGSE J.
D. Townsend, Plant Manager, PGSE R. F. Locke, PGSE D. Taggard, Supervisor, (}uality Assurance, PG&E T. L. Grebel, Regulatory Compliance Supervisor, PGSE News Service, PGSE State of California bcc w/enclosure:
Project Inspector Resident Inspector docket file R. Nease, NRR G.
Cook B. Faulkenberry J. Martin bcc w/o enclosure:
N. Smith J. Zollicoffer N. Western
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