IR 05000285/1989046
| ML20005F176 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/28/1989 |
| From: | Barnes I, Ellershaw L, Gilbert L, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20005F169 | List: |
| References | |
| 50-285-89-46, NUDOCS 9001160017 | |
| Download: ML20005F176 (14) | |
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APPENDIX B I
U.S. NUCLEAR REGULATORY COMMISSION i
REGION IV
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NRC Inspection Report: 50-285/89-46 Operatir.g License: DPR-40
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. Docket: '50-285 j
Licensee: '0maha'PublicPowefDistrict(OPPD)
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.1623 Harney Street-Omaha, Nebraska 68102
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Facility Name:
FortCalhounStation.(TCS)
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' Inspection At: FCS, Blair, Nebraska
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Inspection Conducted: November 27 through December 1, 1989
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i Inspectors:
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L./D. Gilbert,~ Re6ctor ITFspector, Materials Date
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andpuality Programs Section. Division of
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Re c r Safety
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LT. E. Ellershaw, Reactor Inspector, Materials Date
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. and Quality Programs Section, Division of
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q R.F C. Stewart, Reactor Inspector, Materials Daye
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)J and Quality Prograns section, Division of r
Reactor S fety Approved:
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7. BWneT/CMTef, T8 tert &ls and Quality Dati
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( Prbgray Section, Division of Reactor Safety
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i Inspection Summary
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-Inspection Conducted November 27 through December 1, 1989 (Report 50-285/89-46)
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Areas Inspected: Routine, unannounced inspection of licensee action on-l previously identified inspection findings, the auditing program, and procurementofcommercialgradeitems(CGIs).
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Results: The licensee has implemented an auditing program that is consistent with the requirements of the Technical Specifications and the Updated Safety
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Analysis Report. The licensee is continuing to make improvements in the
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auditing program as part of the safety enhancement program.
In the area of l
procurementofCGIs,anapparentviolationwasidentified(paragraph 4.e)
pertaining to the failure to establish a program in a timely fashion and the failure to evaluate CGIs for safety-related applications. The inspection l
revealed that OPPD did not establish a formal CGI program until April 1988. A
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review of CGI procurements dated before April 1988, indicated that traceability of parts to actual manufacturers was virtually. nonexistent, that critical characteristics were not sufficiently established, that insufficient inspection /
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testing was performed, and that no audits / inspections /surveillances were performed at the vendors facilities in order to provide some assurance that the pertinent parts of a cuality program were in place in order to provide some
credibility to the attestations of vendor documentation received. With respect to the CGI procurement activity, subsequent to the establishment of a formal program, a significant reduction in these types of problems occurred. The inspectors identified two problems of a similar nature, in which there did not appear to be any documented traceability of purchased CGIs to the original I
equipment seismic qualifications. The inspectors concluded that, while a fair l
amount of improvement had occurred as a result of progr&m implementation, more awareness for the need of an in-depth review during the evaluation and dedication process is required.
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-3-DETAILS 1.
Persons Contacted
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i OPPD
- K. J. Morris, Division Manager, Nuclear Operations
- W. G. Gates Executive Assistant to the President
- G. R. Peterson, Manager, FCS
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- R. L. Jaworski, Manager, Station Engineering j
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- R. L. Andrews, Division Manager, Quality & Environmental Affairs j
- C, J. Brunnert, Supervisor Operations Quality Assurance
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- W. R. Bateman, Supervisor Procurement Quality Assurance
- R. W. Short, Supervisor Special Services
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- J. W. Chase, Manager, Nuclear Licensing & Internal Affairs
- C. W. Norris, Lead Engineer - Special Services
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- J. D. Kecy, Supervisor Systems Engineering
- G. R. Kopecky, Project Engineer
- L. H. Borcherding, Operations Quality Assurance
- D. R. Taylor, Operations Quality Assurance
- C. F. Simmons Station Licensing Engineer i
NRC
- P. Ilarrell, Senior Resident Inspector The inspectors also interviewed other licensee employees during the inspection.
- Denotes attendance at exit interviOW conducted on December 1,1989.
2.
Licensee Action on Previously Identified Items (92701 and 92702)
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a.
(Closed) Violation (285/8908-02):
Failure to provide accurate information to NRC. The licensee submitted a revised response to the subject violation on March 31, 1989, which corrected the inaccurate information. The licensee also changed the procedure for processing of correspondence to NRC. The procedure now requires that correspondence which makes reference to or utilizes information provided by any group not involved in its writing shall be reviewed
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for accuracy and completeness by the group who provided the information. This item is closed, b.
(Closed)UnresolvedItem(285/8840-01):
Fillet welds that may have excessive fitup gap with insufficient effective throat. The inspector verified that the licensee performed an engineering evaluation of existing fillet welds with fitup gaps between 1/16 and 1/8 inches to assure that an adequate weld throat existed to meet the minimum design requirements. The inspector also verified that
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-4-i Standing Order G-72A was revised to include requirements for increasing the fillet weld size when fitup gaps exceed 1/16 inch.
Based on the satisfactory results of the engineering evaluation and
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the revised welding requirements, this item is resolved.
3.
Auditing Program (40702and_40704)
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The objective of this inspection was to verify that the license has developed
and implemented a quality assurance (QA) program relating to audits of ecifications(TSs)and
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activities that is in conformance with Technical Sp(USAR).
commitments in the Updated Safety Analysis Report
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The inspector reviewed the following documents to verify that administrative controls exist which provide measures to assure that audits are scheduled and performed by independent and qualified
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personnel, including appropriate technical expertise when needed.
Quality Assurance Plan Section 10.1, " Audit Program and Audits,"
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Revision 3 Quality Assurance Manual QAM-10. " Conduct of Audits," Revision 0
Quality Assurance Manual QAM-12. " Internal Audit and QA Surveillance
Program Scheduling," Revision 0 Quality Assurance Manual QAM-13, " Training and Certification of Audit
Personnel," P.evision 0 Quality Assurance Manual QAM-20 " Control of Deficiencies and
Corrective Action," Revision 0 Quality Assurance Manual QAM-21, " Deficiency Tracking, Trending and
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Reporting," Revision 2 To assess the implementation of the audit arogram, the inspector reviewed the 1989 internal audit schedule that had been developed for QA and the Safety Audit and Review Committee (SARC). The 1989 audit schedule wrs consistent with the QA Plan requirements and was approved by the Manage-QA/QC and reviewed by the SARC Chairman. The schedule included audits which encompassed the areas and frequencies specified in Sections 5.5.2.8 and 5.5.3 of the TS. As part of the 1989 scheduled audits, the licensee performed a safety system functional inspection (SSFI) of the 120 volt vital distribution system. The licensee contracted ERC Environmental and Energy Service Company to perform the SSFI audit that is scheduled for completion on December 1, 1989. The inspector selected the following audits from the the 1989 audit schedule for review to ascertain adequacy of audit scope, audit content, audit checklist, distribution to e
management, followup actions, timeliness of reports and responses to audit findings, and audit personnel qualifications, i
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SARC Audit No. 45 "Nonconformance/ Deficiency Control and Corrective Action." This audit was conducted from July 17 to August 4, 1989, i
and the report issued on August 18, 1989.
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SARC Audit No. 1. " Quality Assurance Program." This audit was
conducted from February 27 to March 10, 1989, and the report issued i
on April 6, 1989.
QA Audit No. 25A (SARC Audit Report #2-89), " Fire Protection / Loss
prevention." This audit was conducted from February 27 to March 10,
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1989, and the report issued on April 6, 1989.
QA Audit No. 30, " Material Identification and Control." This audit
was conducted from August 21 to September 1, 1989, and the report i
issued on September 29, 1989.
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QA Audit No. 61 (SARC Audit Report #4-89), "Conformance of Facility
Operations." This audit was conductod from June 12 to July 5,1989, and the report issued on July 19, 1989.
SARC Audit No. 62, " Performance. Training and Qualification of Fort
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Calhoun Staff (Operators Training and Feedback of Operating Experience." This audit was conducted from August 10 to August 25, 1989, and the report issued on September 22, 1989.
The audits appeared to be thorough, and the audit reports were distributed to senior management. The inspector selected SARC Audit Report No. 45 to review the negative findings and the responses provided by the audited organization. The responses were considered to be thorough, and corrective actions were implemented in a timely fashion. Only one of the 14 findings was still open, and it was included in the Weekly Deficiency Report / Quality Report (DR/QR) Status Report to senior management with a status of overdue. The timeliness of responses does not appear to be a problem
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because the weekly status report listed 155 active DR/QRs, of which only 4
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were listed as overdue.
In addition to reviewing the above audit reports,
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on November 28, 1989, the inspector witnessed the preaudit conference for
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SARC Audit Report 45 on nonconformance control and the postaudit conference l
for QA Audit Report 29 on shift operations and tagout. The preaudit conference clearly addressed the areas to be audited, and management was responsive to all of the findings addressed at the postaudit conference. The ins)ector also reviewed the qualifications and certifications for members of bot 1
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audit teams for Audit No. 45.
l-The audit program was consistent with the TS requirements and the USAR commitments.
In addition to the audits, the inspector reviewed the surveillance program and the surveillances performed in 1989 for special processes. The inspector was informed that the surveillance program scheduled to begin in 1990, will be changed to implement the functional (,
area expert concept which should provide better coverage between audits and improve the performance based inspection effort.
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-6-No violations or deviations were identified during this portion of the inspection.
4.
Procurement of Commercial Grade Items (CGIs) For Safety-Related Application (38703)
a.
Backcround Certain criteria of Appendix B to 10 CFR Part 50 require that licensees establish measures to assure that suitabic materials, parts, and equipment are selected for use in safety-related systems during the design process and that licensees establish measures to assure the proper procurement of materials, parts, and equipment.
These measures include procurement document control, inspections and audits of manufacturers and suppliers, receipt inspections, and testing of procured items.
In practice, licensees have two basic options for the procurement of items for use in safety-related applications. Licensees can either procure the items as safety-related from a vendor whose quality assurance program has been reviewed and found to address all regulatory requirements or licensees can procure items as commercial grade and then dedicate the items themselves for safety-related use. The dedication process consists of those actions taken by the licensee to gain assurance that the component or part will fulfill its safety-related
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function under any analyzed accident condition, including harsh
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environments and during seismic events, as appropriate. NRC Generic Letter 89-02, dated March 21, 1989, describes methods that the NRC
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finds acceptable for the dedication of CGIs. The methods include audits of manufacturers and suppliers to ensure the presence of quality assurance measures commensurate with the significance of the item being procured, or the performance of special tests and inspections by the licensee to verify the critical characteristics of the item.
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Fort Calhoun Station's CGI Procurement Program During review of Omaha Public Power District's (OPPD) Fort Calhoun Station CGI procurement and dedication program, the inspectors noted that a formal, written program did not exist until April 1988, at which time Engineering Standard GEG-29, " Guideline For Commercial l
Grade Procurement And Dedication," was issued for impicmentation.
Subsequently, the document was cancelled and superseded by General Engineering Instruction'GEI-32, " Instructions For Preparing Material Evaluation Reports And Materie1 Procurement Plans" on June 30, 1989, with the current issue being Revision 2 dated October 3, 1989. The i
major differences between the two documents related to their scope.
GEG-29 pertained exclusively to the evaluation of CGIs for use in safety-related applications, which are referred to at Fort Calhoun Station as Critical Quality Elements (CQEs). The scope of GEI-32 was
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expanded to include not just evaluation of CGIs but all components,
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parts, and services to be used as CQEs. Review of the documents, with respect to the procurement and dedication of CGIs only, revealed a well written and comprehensive program which very closely followed the guidelines contained in EPRI NP-5652, " Guideline For The Utilization of Commercial Grade Items in Nuclear Safety-Related Applications (NCIG-07)," which has been conditionally endorsed by the
NRC. In order to determine the extent of CGI procurement, the
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inspectors requested the licensee to provide data which would show CGI procurements prior to, and after, implementation of GEG-29 and
GEI-32. Computer printouts and a handwritten log were provided which covered the periods December 1985 through October 1987 (prior
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to program implementation), October 1988 through Jul by GEG-29), and from July 1989 to the present time (y 1989 (governed governed by
GEI-32). The inspectors noted that the licensee had made only
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limited use of CGI procurement.
In order to verify this, the inspectors requested a printout showing all planned procurements,
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known to date, for the refueling outage scheduled to begin in February 1990. The printout showed, among other things, the purchase order (PO) number (if placed), vendor, line item nomenclature, and
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classification (i.e., CQE or CGI).
It did not show the individual line item quantities; however, a comparison was made between the number of line items designated as CGI and the number of line items
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designated as CQE. This comparison revealed that approximately 8 per cent of the planned line items to be procured were designated
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as CG!s. To further verify the validity of the designations shown on the printout, the inspectors selected 36 line items associated with 10 P0s, all designated as CQE, but in the inspectors' opinions, the t
most likely candidates to be procured as CGI. The inspectors were
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provided with copies of the 10 P0s. Review of the P0sshowed that each of the 36-line items had indeed been ordered as CQE, with all of the appropriate statements pertaining to Appendix B to 10 CFR Part 50 l
and 10 CFR Part 21 included.
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CGI Procurement Prior To Program Implementation l
In order to determine the actions taken by the licensee with respect to CGIs procured for CQE application prior to the establishment of a j
formal program, the inspectors selected seven P0s from the printout
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covering the period December 1985 through October 1987. Of the seven
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PO packages reviewed, two appeared to be adequate in that the items were purchased from the original equipment manufacturer with the l
original specifications and requirements imposed, four exhibited a virtual nonexistent dedication effort, and one showed an insufficient dedication effort. The five PO packages exhibiting problems are as
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(1) P0 C097855 dated March 20, 1987, to Great Plains Industrial
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l-Supply Co., Inc., (GPI) in Ome.ha, Nebraska, for three line items
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of 200 each various size fasteners (i.e., bolts and machine
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.g-screws, with corresponding nuts and flat washers, of SAE Grade 2
material). The P0 stated that these items are being purchased i
for bypass transfomer replacement on Maintenance Request MR-FL-86-16 and that a Certificate of Conformance (C of C) is
required attesting that all material furnished meets SAE Grade 2 requirements. The fasteners were received and accepted on-
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March 24, 1987, based on receipt inspection being performed on a sample, and the receipt of a C of C.
The receipt inspection consisted of a verification of the identification marked on the package (s), shipping damage, cleanliness, and a dimensional
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check. The undated C of C from GPI references OPPD's P0 and
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certifies that all material furnished complies with the material
description requirements stipulated on the P0. There was no
documented, verifiable, traceability of these items to the
actualmaterialmanufacturer(s),andtherewasalackofadequate i
inspection and/or testing performed to verify critical characteristics (i.e.,materialproperties).
Furthermore, review of the 1986 and 1987 Routine Suppliers List (RSL), which is a listing of OPPD's approved nuclear suppliers and their applicable materials, parts, or services, revealed that GPI was not on the RSL.
(2) P0 C097976 dated June 4, 1987, to BOSCO Fastening Service Center, a Division of RB&W Corporation, Omaha, Nebraska, for 500 each 1/2-inch by 3-inch bolts, hex head, SAE Grade 5.
The P0 indicated that these are being purchased as CGIs for a CQE applicatior, associated with ATWS (Anticipated Transient Without Scram)RuleModifications,onMR-FC-84-203. The P0 also required the vendor to provida a C of C certifying that all material furnished complies with SAE Grade standards. The bolts were subsequently received, inspected and accepted on June 5, 1987, based on receipt inspection and a C of C.
The receiving inspection consisted of a check on damage, cleanliness,
identification, and protective devices. According to the
associated Receipt Inspection Checklist, a sample size of 50 was selected to verify threads, dimensions, physical appearance, and material identification. The checklist shows that the bolts
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were identified in accordance with fastener specification ASTM A L
449-78a with a remark that there are 3 radial lines 120 degrees apart with the manufacturers symbol KY. The undated C of C is from RB&W Distribution Division, attesting to the fact that the
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500 bolts, to the best of their knowledge, were produced in i
accordance with the applicable specifications designated on the P0. There was no documented, verifiable, traceability of these
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bolts to the artual material manufacturer (s), and there was i
inadequate inspection / testing performed to verify critical j
characteristics (i.e., material properties).
In addition, review of the 1986 and 1987 RSL revealed that neither BOSCO Fastening Service Center nor RB&W Distribution Division were on the RSL.
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(3) P0 SO 19715 dated May 11, 1987, to General Electric Supply
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Company (GESCO), Omaha, Nebraska, for five each Luxiliary switches, GE Type SBM 10AX006G4, for 4160 volt switchgear. The P0 specified that these items were being purchased hs CGIs for CQE application. Both the purchase requisition and the receiving report stipulate that Engineering was to provide a justification letter for a "one to one" replacement. OPPD's
definition for "one to one" replacement, as described in GEI-32,
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is an item which, amongst other things, has the same
-manufacturer and has identical physical and )erformance
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characteristics to the item it is being purciased to replace.
The items were received, inspected and accepted on September 2, 1987, based on a receipt inspection consisting of physical o
appearance (damage), packaging,-itemidentification connections, andanengineeringjustificationletter(FC-1004-87} dated June
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23, 1987, which addressed the fact that two of the switches will
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be used to replace two installed switches found to be defective.
It further states that the new switches will perform the same form, fit, and function as the originals. The only vendor documentation associated with these switches is a packing slip from GESCO which showed that five switches with part number 10AX006G4 were shipped. There was no documentation available i
which would substantiate that the switches were not remanufactured and that they were from the original manufacturer, and that they
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had identical physical and performance characteristics to those i
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that they were purchased to replace. Critical characteristics relating to materials and performance were not established, thus, precluding any further acceptance activity. Review of the 1986 and 1987 RSL revealed that GESCO was not on the RSL.
(4) P0 5019921 dated May 14, 1987, to GESCO, Omaha, Nebraska, for two each Switches, GE Type 16SB1EB4C83SPR2P. These switches l-were purchased as CGIs to be used in a CQE application (i.e.,
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contacts 6 and 6C of permissive switch IB30-4C-4 associated with i
l the AC-3C breaker in the component cooling water system) as
shown on Maintenance Order 872012. The switches were received, and inspected and accepted on September 1, 1987, based on a
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receipt inspection consisting of a review of markings, packaging, cleanliness, lack of apparent damage, and, as above, a similar engineering justification letter FC-1326-87, dated
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August 27, 1987. The only available vendor documentation consisted of a packing slip from GESCO which showed two switches of the same part number. There was no documentation which would substantiate that the switches were not remanufactured or were from the original manufacturer and that they had identical l.
physical and performance characteristics to those that they were purchased to replace. Critical characteristics were not established and no further acceptance actions were specified.
As stated previously, GESCO was not on the RS.
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i (5) P0 S012973 dated October 3, 1986, to Satin American Corporation,
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for two each GE AK2A-25 Low Power Circuit Breaker (600 amp, 600 i
volt, 3 pole) manually operated with 250 Amp trip rating. These i
breakers were purchased as CGIs for CQE application (i.e.,
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replacementsforvacuumdeaeratorpumps)onMR-FC-82-150B. The-t P0 required a C of C, including serial numbers, a certified copy of Satin American's factory acceptance test, and a copy of all
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technical, maintenance, and installation manuals. The items were
subsequently received, and inspected and accepted based on the typical receipt inspection (i.e., identification and marking,
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documentation, lack of physical damage, cleanliness, and i
packaging).
In addition, an engineering justification letter,
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GSE-FC-86-1029 dated September 22, 1986, was included in the i
receiving inspection package. This letter stated'that because
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the load centers were manufactured by GE, then the new circuit
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breakers must be manufactured by GE in order to be com>atible.
However, it was noted that GE no longer manufactured tiese breakers, but that Satin American had breakers which were new and identical to the original breakers supplied by GE.
It further stated that in order for the circuit breakers to be
dedicated as CQE, the following testing must be performed:
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(b) Visual testing (c) dnsite calibration per procedures CP-DW46A and CP-DW46B
Satin American's submitted documentation included a Certificate of Compliance dated October 17, 1986, and two breaker test reports, one for each serial numbered breaker, dated October 13, 1986. Receiving inspection was conducted and completed on
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January 28, 1987. The breakers were subsequently installed, l
however, the exact date was not established. The inspectors
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requested documentation which would satisfy the onsite i
calibration requirement specified in the engineering justification letter. Copies of the completed calibration procedures were provided and it was noted that the final sign
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off dates were January 2 and 3,1989, which is considerably after the time that the breakers were installed.
In any event, as a result of NRC Information Notice 89-45, Supplement 1,
"Metalciad, Low Voltage Power Circuit Breakers Refurbished With
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Substandard Parts," these installed breakers were inspected in August 1989. The results showed differences between authentic
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breakers. It was also observed that the instantaneous trip settings had been changed. To alleviate the concern as to the I
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breakers' interrupting capability, the licensee performed Calibration Procedures CP-0W46A and B, with no problems being L
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identified. However, the NRC has determined that testing of the breakers may not always reveal the latent problems that can
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exist with the breakers (i.e., failure to trip). The inspector
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was informed by the licensee's licensing staff, that in order to
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resolve these concerns, the licensee removed the breaker from i
I Pump DW-46B and replaced it with a spare breaker previously received from GE. The breaker was not removed from Pump DW-46A, l
however, the cubicle drawer is partially engaged and has been
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tagged out by the shift supervisor. The inspectors were also
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informed that the licensee returned the breaker from Pump DW-46B to GE in order to have it refurbished to original CQE i
requirements. The licensee stated that they were informed by GE
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that the breaker could not be brought up to CQE standards because it was originally manufactured as a nonsafety-related l
item and supplied to a company other than Satin American. At this time, the circumstances as to how Satin American acquired
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these breakers and subsequently were able to supply them as CQE
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items are not known. Similar to the vendors in the previous examples, Satin American Corporation had not been surveyed or audited by the licensee and was not listed on the RSL,
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Part of the above discussion was excerpted from NRC Inspection
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Reports 50-285/89-32 and 50-285/89-38 in order to provide clarity and continuity.
d.
CGI Procurement After Program Implementation The inspectors reviewed the hand written log and printouts in order to select a sample of CGI procurements made after the implementation of the program (i.e., GEG-29 and gel-32). A total of 11 P0 packages were selected and reviewed. Of the 11 packages, 2 exhibited an incomplete dedication and are discussed as follows:
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(1) P0 SO46624 dated June 8,1989, to Process Measurement Company, l
Omaha, Nebraska, for six each meters, P/N 180-145 LSRS-7, Type 180, 0-250 Amp Scale, Horizontal mount, left hand zero, and
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transformer rating of 250/5. The P0 stated that the items are
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to be a commercial grade dedication to CQE purchase.
It also required that receipt inspection was to verify the meter type as specified in commercial grade dedication FC89-21 GEG 29.5 BB2, and that a C of C was required certifying that all material furnished meets the PO description and requirements. The Receipt Acceptance Plan also required Quality Control to verify dimensions per the attached drawing and to witness the calibration of the instruments. Subsequently, it was identified during receiving inspection that the part number on the C of C did not agree with the part number on the P0, and the C of C did not reference the OPPD PO number nor did it attest that the parts met the P0 description and requirements. These findings resulted in the issuance of Material / Equipment Nonconformance
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i-12-Report (NR)89-071 dated August 17, 1989. On September 26, i
1989, the NR was completed with a " Accept As Is" disposition.
The disposition was based on a Yokogawa facsimile letter to Process Measurement Company dated August 11, 1989, and an amended C of C.
The Yokogawa letter addressed the difTerences in part numbers by stating that if the number ended in a 1, then the part was manufactured by GE, and if the part number Ended in a 7, it was manufactured by Yckogawa to the design requirements of GE.
If the part number ended in an 8, then the part was manufactured by Yokogawa, but with some change. To further hel explain, the package also contained a "To Whom It May Concern" p letter from Yokogawa Corporation of America dated March 14, 1989, which also addressed the meaning of the part number changes.
In January 1985, Yokogawa acquired General Electric's Instrument Products Section and started to manufacture GE branded products. They stated that even though the format for the part numbers changed minutely, the finished products represented by these numbers are form, fit, and function replacements for the GE products. With res)ect to the C of Cs, the original and the " amended" one are bot 1 dated July 20, 1989, and signed by the Quality Control Supervisor at Yokogawa.
The amended one does not have the word amended, or similar, entered. However, it was noted that the amended one is not a copy of'the original, but is of a different format, and further, thedifferentinformation(i.e.,OPPDPOnumberandpartnumber differences) was apparently entered by a representative of Process Measurement Company as evidenced by his signature at the location of the part number change explanation.
It was also noted by the inspector that commercial grade dedicationFC-89-21GEG29.3(1)and(2)statesthatthe original meters were installed in control panels CB-10 and CB-11 at the time that the panels were seismically qualified and since these meters are built to the original design, there is no effect on the original qualification. The inspector requested OPPD to provide documentation which would clearly demonstrate that no changes had occurred since the original meters had been manufactured by GE, and which would also provide traceability of these meters to the original seismic qualifications. This information was not presented to the inspectors.
Review of the RSLs for 1988 and 1989 revealed that neither Process Measurement Company nor Yokogawa Corporation of America had been listed as an approved supplier or manufacturer.
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(2) P0 SO42766 dated February 7,1989, issued to Process Measurement Company, Omaha, Nebraska for six each meters,10/50 Mil 11 amps, GE/Yokogawa P/N 185111HYHY1AAS. The P0 stated that these items are to be commercial grade to CQE purchase and that the receipt inspector is to verify that the meter type is as specified in
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commercial grade dedication traveler FC89-04 GEG 29.5 BB2,
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Attachment 1.
A C of C was also required certifying that all
material furnished meets the P0 requirements and the catalog
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s>ecifications. Traveler FC89-04 GEG 29.5 BBE saecifies the c1aracteristics to be verified, which included tie part number, alldimensionscircledonthedrawing(Attachment 1),andthe
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performance of a 3 point meter verification test.
The meters were received and inspected with respect to part number verification and dimensions, on April 20 and April 29,
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1989, respectively. The 3 point meter verification test was performed and the meters accepted on June 26, 1989. A Yokogawa C of C dated April 18, 1989, was also included in the package.
The inspector noted what appeared to be changes made to the r
Yokogawa C of C with respect to the addition of the OPPD P0 number and a part number change. The C of C showed the part number to be 185111HYHY7AAS which is different than the.-1AAS
specified on the P0. As in the above case, the "To Whom It May
Concern" letter dated March 14, 1989, was included in the PO package, and the change with respect to the part number on the C of C had been signed by the Process Measurement Company representative. The inspector also noted that comercial grade traveler FC890-04 GEG 29.3 Part (1) and (2) showed that the i
original meters were supplied as an installed item in a seismically qualified control panel and since these new meters were the same as the originally supplied meters, then no adverse effect on the
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seismic qualifications had occurred. As in the above case, no i
documentation was )rovided which established that the meters
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were the same as tie originally supplied meters and no documentation was provided which established traceability of these meters to
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the seismic qualifications. As stated previously, neither Process Measurement Company nor Yokogawa Corporation of America i
were on the RSL.
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e.
Conclusion
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The information obtained during this inspection reflected the absence of a formal CGI procurement program prior to April 1988. With respect to four of the five examples in this category and discussed
above in paragraph 4.c, traceability of the parts / material could not be established to the manufacturer, critical characteristics were not sufficiently established, insufficient inspection / testing was performed, and no audits / inspections /surveillances were performed at the vendors facilities in order to determine if the applicable elements of a quality program were in place which would at least
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provide some measure of assurance with respect to the validity of vendor documentation received. With respect to the fifth example, even though it appears that critical characteristics had been
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I established and testing performed, and appropriate documentation was -
i requested and received, it was shown to be not adequate in that OPPD'
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had no knowledge of the vendor based on direct observation through
audits or similar mechanism, in order that the validity of vendor documentation could be established.
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With res>ect to the CGI procurement activity subsequent to the
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establisiment of a formal program, two examples, discussed above in
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f paragraph 4.d. were identified in which an incomplete dedication was performed (i.e., failure to establish traceability of the items receivedtotheoriginalequipmentseismicqualifications),anda failure to establisi the existence of a manufacturers and a suppliers program in order to have some assurance that the provided
= documentation was valid.
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In addition, it was established through review of RSLs and
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discussions with cognizant personnel, that, with one exception, no
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audits / inspections /surveillances have been performed on CGI vendors.
Therefore, prior to April 1988, OPPD had not established documented measures with respect to evaluation of CGIs for safety-related
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application, and once having established the measures, did not
. implement them in all cases. These examples are an apparent violation of Criterion III of Appendix B to 10 CFR Part 50.
(285/8946-01)
5.
Exit Interview i
An exit interview was conducted on December 1, 1989, with those personnel
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denoted in paragraph 1 in which the inspection findings were summarized.
No information was presented to the inspectors that was identified by the licensee as proprietary.
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