IR 05000424/1986022
| ML20215B609 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/26/1986 |
| From: | Belisle G, Jackson L, Moorman J, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215B591 | List: |
| References | |
| 50-424-86-22, NUDOCS 8612120249 | |
| Download: ML20215B609 (12) | |
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET, N.W.
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Report No'.:
50-424/86-22 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name:
Vogtle 1 Appendix 21C:
Procurement Inspection Conducted: March 24-28, April 21-25, and June 2,1986 Participating NRC Offi es: None Inspectors:
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L.H.Japson,ReactorInspector,RegionII Date Signed N.1l 1TlHk.n J-10 -86 H. Moo an, Reactor Inspector, Region II Date Signed Approved by:
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G.CA. Belisle' Acting Section Chief Date / Signed
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Division of Re tor Safety, Region II h
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M. V. Sinkule, Chief : Projects Section 2D Dat'e Signed Division of Reactor Projects, Region II 8612120249 861202 DR ADOCK 05000424 PDR j
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TABLE OF CONTENTS Topic Page Sunnary 3-4 Scope of Review
Methodology 4-5 Evaluation 5-8
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Findings 8-11 Conclusions 11-12
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Sumary Appendix 21C, Procurement, was developed by eight _ individuals having more than 90 years of combined experience in nuclear power plant procurement, quality assurance (QA), and vendor surveillance.
An appendix verification checklist was used during this activity.
This verification checklist was developed by taking into consideration problem areas identified from past audits performed by Bechtel Power Corporation (BPC); Georgia Power Company (GPC) Quality Assurance (QA); Institute of Nuclear Power Operations (INP0); Southern Company Services (SCS); and the Nuclear Regulatory Comission (NRC).
The Readiness Review program was initiated to determine whether licensing comitments were properly implemented in project procedures and to determine whether evidence existed throughout the procurement process to verify it was in compliance with comitments.
To implement the above, the Readiness Review Staff (RRS) identified comitments and project policies.
Procedures were reviewed to ascertain whether they properly incorporated the comitments. Project procurement records were reviewed to ascertain whether these documents demonstrated compliance with procedures and implemented comitments.
The document types that were included in the procurement review were purchase orders, change orders, field change requests (FCRs), and specifications.
Based on this review, two findings (C1 and C2) were identified as Level II by the RRS.
Finding C1 involved discrepancies in the administrative processing of procurement documents.
Objective evidence was not available to verify that QA reviewed field change reque:ts; changes were issued without attaching the latest revision of the applicable specification; and modifications were made to procurement documents without evidence of requisitioner review.
The inspectors reviewed the above discrepancies and concluded that the licensee had properly evaluated the discrepancies as administrative.
Therefore, no deficiencies were identified with the hardware.
Hence, no safety significance was identified with these discrepancies.
Finding C2 involved five areas.
Four of these areas required clarifying the program, in that procedures were revised to define responsibility for taking procurement actions.
These revisions were considered an enhancement in the program and no failure to implement an adequate procurement program was identified by the RRS.
The other area of this finding involved procedural inadequacies that could have resulted in inadequate material or equipment being purchased because objective evidence of supplier qualifications was not available at the time of purchase.
Therefore, material or equipment could have been furnished and installed which would not have served its intended safety functio.
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Finding C3 was considered Level III by the RRS with no impact on the quality of items purchased.
This discrepancy was the result of procurement documents being issued at different periods in time. The inspectors concluded that there were no hardware deficiencies. The licensee's evaluation was considered adequate.
NRC inspectors reviewed Appendix 21C, on site during March 24-28, April 21-25, and June 2, 1986.
Minor typographical errors were identified during the March 24-28,1986 inspection.
These errors were adequately corrected in a GPC submittal dated April 7, 1986.
No violations, deviations or deficiencies were identified. The minor errors did not represent significant programmatic weaknesses.
Details on the above findings are discussed in the body of this report.
1.
Scope of Review This review, which consisted of an examination of each section of Appendix 21C, was performed by inspectors from Region II. Sections C1, C2, C4, C6 and C8 of Appendix 21C, which present data on the appendix scope, responsible organizations, program description, program changes, and conclusions regarding the assessment of the appendix, did not require as detailed a review or evaluation as the other sections. The more significant aspects of the appendix are in sections C3, C5, and C7.
These sections discuss licensee commitments and implementation, audits and industry problems, and procurement verification.
Review of these three sections was more in depth and included an examination of items identified as findings regardless of their final level of classification. The inspectors examined a sample of procurement documents reviewed by the RRS and also examined an independently selected sample of documents to assess the thoroughness of the overall evaluation.
Procurement of materials and equipment which is controlled by BPC home office was not evaluated in this Appendix.
Methodology used for this review and an ev<luation of each section are presented in the following paragraphs.
2.
Methodology The technical review and evaluation of Appendix 21C was conducted in the Region II office during the weeks of March 10-20, 1986, and was supported by onsite inspection activities during the weeks of March 24-28, April 21-25, and June 2, 1986.
The office review of section C3 compared the applicant's accepted QA program licensing commitments with the Standard Review Plan (SRP) (NUREG-0800)
positions, regulatory guides, industrial codes, IE Information Notice 85-52, American National Standard Institute (ANSI) Standards, and Vogtle Final Safety Analysis Report (FSAR) documents.
While onsite the inspectors reviewed section C4, Program Description, to determine if responsibilities and work processes described therein were being implemented as written.
GPC procedures were reviewed to determine if
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they contained implementing requirements necessary to evaluate the adequacy of their procurement program.
Audit reports and RRS findings were reviewed to determine the significance of the problem areas identified and the effectiveness of the proposed corrective actions or corrective actions taken.
Selected specifications and procurements were evaluated under individual modul es..
The inspectors examined the RRS's original working checklists for depth of review and extent of detail that was applied to evaluate the adequacy of the procurement program.
3.
Evaluation The evaluation of each section of Appendix 21C is provided below. For each section, a description of the section, what was reviewed, and the basis of acceptance are provided,
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a.
Section C1 - Scope This section included a description of the procurement program in effect as of Mry 1, 1985. It addresses the qualification and selection of purchased safety-related items, surveillance at manufacturing facilities, and expediting activities.
This section was reviewed for background information only.
The enhancement portion of the program is addressed in section C7.
No other followup or evaluation of this section was required.
b.
Section C2 - Responsible Organizations This section reiterated the licensee's responsibility to maintain overall management of procurement at Vogtle Electric Generating Plant (VEGP).
Participating in this procurement process were GPC, SCS, and BPC. At the time of the inspection, SCS did not procure safety-related items; therefore, their participation was evaluated only as it related to supplier quality surveillance, supplier audits, and expediting.
This section was reviewed for background information and for a general understanding of the interfaces between participating organizations.
These interfaces and the effectiveness of the program are discussed in section C7. No followup of this section was required.
c.
Section C3 - Commitments and Implementation The inspectors reviewed the 11 procurement connitments identified by the RRS in the commitments table to confirm that they were the same as those connitted to in the FSA e
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Procedures listed under " Design First" in the appendix implementation matrix were reviewed to confirm that they incorporated appropriate comitments.
" Design Last" procedures were also reviewed to assure comitments were reflected in working procedures as of May 1,1985.
Typographical errors noted in these comitment and implementation matrices were corrected by the licensee's submittal of April 7,1986.
FSAR Chapter 17A.0, Introduction, states that the program was responsive to the intent of ANSI N45.2.13, Supplementary Quality Assurance Requirements for Control of Procurement of Equipment, Materials and Services for Nuclear Power Plants (Draft dated 5/31/73).
Review of this section by the NRC inspectors identified that Vogtle's licensing comitments and implementing documents comply with the FSAR, SRP, RG, and industry codes and standards.
d.
Section C4 - Program Description This section of the appendix provided a sumary description of the project procurement program.
Responsibilities of participating organizations for evaluation and selection of bidders; processing of proposals; preparation, review, approval and issue of requisitions, purchase orders, and purchase order change notices; source surveillance inspection; and expediting of drawings, documentation, and hardware were defined to ensure that interfaces between these organizations were consistent with comitments.
For American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code items used in pressure retaining applications, the material supplier was required to hold an ASME Material Supplier or Manufacturers quality system certificate, or be an approved supplier on the BPC Evaluated Supplier List (ESL).
For other than pressure retaining materials covered by ASME B&PV Code, the bidder was required to be approved by BPC or GPC and listed on the Qualified Supplier List (QSL).
When normal receipt inspection cannot be used to confirm acceptability of materials, source surveillance inspection and audits are required by specifications.
The SCS Project Quality Assurance Engineer (PQAE)
reviews and evaluates BPC recommendations for surveillance and when required, prepares the surveillance plan which establishes witness and hold points that the BPC Supplier Quality Representative (SQR) is required to witness.
The level of surveillance assigned to specifications was dependent on the complexity of the material and past history of the manufacturer.
Annual quality program evaluations were conducted by SCS QA.
The triennial audits required by RGs were coordinated by SCS and performed by SCS or BPC or a combination of both organization.
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GPC Project Procurement was responsible for management of the expediting function of the three participation organizations.
Review of.this section confirmed that the program description was correct and in agreement with FSAR and project requirements.
e.
Section C5 - Audits During.the design and construction of VEGP, the. procurement process was audited by GPC QA, SCS QA, BPC QA, INPO, Westinghouse Corporation, and the NRC to determine if the procurement process was in compliance with commitments.
The RRS reviewed historical files of audits performed at VEGP. Problem areas identified by this review were tabulated as' findings in the audit findings matrix.
The more significant past audit findings from this matrix were further identified.
This information was used by the RRS in developing the verification scope and checklist used in this
appendix.
l Review of this section indicated that it was an accurate presentation of deficiencies within the procurement program.
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The Standby Diesel Generator industry problems were not evaluated by
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the inspectors, based on the more expert attention to this equipment by others in the NRC and the industry,
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Section C6 - Program Changes There have been relatively few changes in the procurement program at VEGP.
The more significant changes involved incorporation 10 CFR Part
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21" requirements effective August 15, 1978; and GPC's decision to transfer procurement responsibilities to the jobsite in 1984.
Review
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of other changes confirmed implementation of criteria established by
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NRC, or were administrative.
The major changes to the procurement program were reviewed by the inspectors and the determination was made that these changes did not
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significantly reduce commitments in the program.
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Section C7 - Program Verification The procurement program verification was performed by RRS to determine l
if licensing commitments had been implemented on the Vogtle project, and whether controls existed, and had been used for the procurement of i
safety-related equipment, material, and services.
Procurement activities to be performed by the GPC Nuclear Operations Department after fuel load were addressed in Module 5.
Since Module 5 had already been reviewed by NRC, no evaluation of procurement by the Nuclear Operations Department was accomplished during this inspection.
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The RRS verification team compared a representative sample of engineering specifications for equipment and materials against purchasing documents prepared by Bechtel Power Corporation (BPC) and by GPC Construction. The RRS also traced the procurement actions taken by the responsible engineering, purchasing, and supplier quality organization to determine if purchased items conformed to procurement documents requirements and licensing commitments.
The RRS verification process consisted of a review of 1) procurement procedures, 2) specifications, 3) supplier quality surveillance and audit reports, 4) past QA audit reports, and 5) a review of supplier document submittals and supplier qualification programs.
The primary data collection method was an examination of source documents and records supported by interviews and discussions with respons1 ole individuals.
(1) Procurement Procedures Finding C1, Level II The review of project procurement procedures conducted by the RRS, resulted in a finding which is discussed in parts (a) & (b) below:
(a) Some supply requisitions and request for change orders did not contain objective evidence of project construction QA review.
The NRC inspector evaluated these 17 request-for-change orders which did not contain objective evidence of QA review and confirmed that the changes were administrative or commercial as stated by GPC.
These changes could not have had an adverse effect on the hardware.
(b)
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Some purchase orders and change orders were issued without the current revision to the specifications being included in these orders.
This deficiency was identified against the operations organization.
Since Module 5, Operations Organization and Administration, addresses procurement activities after fuel load, and this Module had already been reviewed by NRC; na evaluation of this problem was conducted under Appendix 21C.
2)
The inspectors reviewed objective evidence to confirm that the latest revisions of specifications were transmitted to manufacturers or that no material was on order at the time specifications were revised and issue m J
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Based on the fact that Bechtel did transmit specifications directly to manufacturers and these manufacturers were working to current revisions of the specifications, the inspector concluded that there was no adverse impact on material or equipment.
3)
The latest specifications were not transmitted to some manufacturers.
The inspectors verified that fabrication at the vendors shops was complete or none was ongoing, therefore the specifications did not need to be transmitted to the manufacturers.
Finding C2, Level II, Part 2-CA The RRS identified that - field procurement procedures were:
informally controlled, lacked clear or ccmplete measures, lacked evidence of training for-buyers, lacked an adequate tracking system for supplier documents, and' lacked explicit direction for procurement-initiated modifications.
The inspector reviewed the revised Project Procurement Manual and objective evidence of training to these revised requirements, and concluded that these changes implemented adequate corrective actions to preclude further deficiencies in this area.
The Region II inspectors reviewed objective evidence of procurement requisitions generated by responsible individuals in
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engineering and verified that these requisitions were used to develop purchase orders.
Buyers-at GPC did not initiate purchase orders without appropriate engineering input.
Administrative changes such as quantities, cost per item, deletion, or cancellation of items and correction of typographical errors in orders were implemented by some buyers.
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l Since these types of cha ges to procurement activities do not
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compromise quality, they are not considered to be significant.
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i Finding C2, level II, Part 2-CB The inspectors considered Part 2-CB of finding C2 to encompass the
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potential for a significant QA breakdown.
Therefore, a detailed i
review of the types of material procured from these vendors was j
performed to evaluate their potential to perform intended safety functions.
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This detailed review confirmed that welding electrodes had been purchased from four vendors not listed on GPC's QSt.
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these vendors were not listed on GPC's QSL at the time purchase
orders were placed, they would have been accepted if GPC had I
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performed an audit of the vendor's program.
The material from vendors such as Unibraze, Alloy Rods Division, Allegheny Ludlum, and Teledyne-McKay were on the BPC ESL or held Materials Supplier Certificates from ASME.
The evaltations performed by the RRS were reviewed by tha NRC inspectors to ensure that the material furnished was confirmed to be acceptable.
These welding electrodes, even though furnished from suppliers which were not listed on GPC QSL, were verified through receiving inspection to be acceptable.
However, one violation was identified during the review of vendor certified materials test reports as discussed in NRC Inspection Report No.
50-424/86-58.
This violation will be evaluated during subsequent inspections.
l Closure of this violation will be confirmed to the satisfaction of the NRC prior to licensing for operations.
Other suppliers were selected at random and documents of the RRS evaluations reviewed.
The inspectors concluded from this review that controls implemented by GPC had been sufficient to prevent j_
deficient material from being received at VEGP.
i Calibration services purchased from unapproved suppliers are evaluated in Appendix 21G, Measuring tnd Test Equipment.
(2) Specifications The inspectors reviewed the specifications listed in paragraph C7.1.3, Procurement Specification Review.
This review confirmed that 10 CFR Part 21 had been incorporated into procurement documents subsequent to NRC Regulations being issued.
Additional specifications were selected for independent review by the inspectors.
This review confirmed that appropriate technical data, seismic data, operating pressures, operating temperatures, environmental data, ASME Code classes, drawing submittals, vendor's witness and/or hold points, and records to be transmitted to GPC were included in specifications. The review also confirmed that ASME design specifications had been reviewed and approved by one or more Registered Professional Engineers as required by ASME B&PV Code NA-3250.
(3) Supplier Quality Surveillance and Audit Reports The inspectors reviewed audit reports of suppliers and verified that the audits were effective in that they identified problem areas and that responses to these problems were evaluated for implementation of corrective action n
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Surveillance reports were reviewed to verify that contract requirements were being inspected by Supplier Quality Representatives (SQR) during shop inspections.
SQR releases were verified to be on file, where required, and were used by receiving inspection personnel to confirm that equipment / materials conformed to procurement contract requirements.
(4) Past QA Audit Reports Audits by GPC QA were selected by the inspector to verify that the audits were meaningful and were implementing a program to evaluate the adequacy of the procurement program in accordance with ANSI N45.2.2 and N45.2.13.
Audit Finding Reports -(AFRs) identified deficiencies in the program.
These AFRs were reviewed by the inspectors to confirm that adequate implementation of corrective action had been accomplished.
Some recurrence of deficiencies was noted.
However, GPC QA was persistent in their followup to confirm that adequate corrective action was implemented.
The inspectors concluded that GPC QA has implemented an adequate audit program to review and evaluate the Procurement Program.
(5) Review of Supplier Document Submittals The inspector randomly selected documents from the record storage vault to verify that documents were received, reviewed, approved, and retrievable.
Where the licensee had identified problems with documentation, adequate followup with vendors was implemented to correct the identified problem.
The document review group that has responsibility for review and approval of documents was verified to have been trained in their functions. This group is adequately trained and very dedicated to implementing a quality review.
6.
Conclusions:
The NRC has reached the following conclusions relative to procurement, source surveillance inspection, and procurement records for Vogtle 1.
With the exception of those items / areas discussed earlier, we have determined the following to be acceptable:
Comitments - The NRC reviewed the comitments as listed in Chapter 3 of the Readiness Review Appendix.
We have determined that the comitments are clearly identified and accurately reflect the source of the GPC comitments.
The matrix is comprehensive and provides an accurate reference to proper ASME codes, regulatory guides, ANSI i
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Standards, or other applicable regulatory documents.
With respect to the implementation matrix, we confirmed that the commitments were reflected in the appropriate design, construction, and procurement procedure.
Program - The NRC reviewed the description of your program as given in section 4 of the module.
The following areas of your program were reviewed:
Specifications.
Supplier quality surveillance.
Supplier quality evaluations.
Supplier audits.
Document submittals.
We have determined that your program description in section 4 accurately reflects past and current programs involving procurement.
Your programs conform to your coreitments and are consistent with implementing procedures.
Audits and Industry Problems - We have reviewed the section on audits and concluded that GPC had an acceptable audit program.
The audits were conducted in accordance with Appendix B and implementing procedures.
The audits were comprehensive and performed in a timely manner.
The audits were in sufficient detail to identify significant problems including root causes.
Audit findings were identified to management, evaluated, and tracked until resolved in an acceptable manner.
Procurement Verification - GPC performed a program verification by reviewing a representative sample of engineering specifications for equipment and material with purchasing documents prepared by Bechtel Power Corporation (BPC) and by GPC Construction.
GPC also traced the procurement actions taken by the responsible engineering, purchasing, and supplier quality organization to ascertain whether purchased items conform to procurement documents and to the licensing commitments.
The verification of procurement identified three findings, and these were categorized on the basis of their individual significance and cumulative programmatic effect.
These findings were reviewed by the NRC and evaluated as acceptable.
This conclusion was based upon an evaluation of the analysis by the RRS, review of supporting information, previous NRC inspections, and the inspectors' judgement.
Based on the reviews performed by the NRC of Appendix 21C, Procurement, the evaluation of findings identified by the RRS, and the independent sample of procurement activities selected and evaluated, we conclude that GPC has implemented an adequate procurement program.