IR 05000498/1990002
| ML20012B231 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/22/1990 |
| From: | Barnes I, Boardman J, Ellershaw L, Gilbert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012B229 | List: |
| References | |
| 50-498-90-02, 50-499-90-02, GL-89-02, NUDOCS 9003140012 | |
| Download: ML20012B231 (12) | |
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{ i . s - f "~ ; 4 . APPENDIX B h.S2 U.S. NUCLEAR REGULATORY COMMISSION.
-REGION IV y > t . . t
NRC Inspection Report: 50-498/90-02 .0perating Licenses: NPF-76
M z.3 50-499/90-02 NPF-80.
! ' - Dockets::. 50-498 ' ,50-499-t a , Licensee: HoustonLighting&PowerCompany(K.&P) ! '" P.O. Box 289-
Wadsworth,.TX 77483 , .
Facility 'Name:' SouthTexasProject(STP), Units 1and2= ' Inspection'At:' STP, Matagorda County, Texas '\\ . Inspection Conducted:. January 8-12, 1990 O M iO Inspectors:. F
~ .. E. Ellershaw, Reactor Inspector, Naterials Ddte / . and Quality Programs Section, Division of Reactor Safety , . , , I Dl;tp/99 '" '
L. D. Gilbert, Reactor Inspector -Materials Date ' ' and Quality Programs Section Division:of
Reactor Safety .r.
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om p ,R; Boardman, Reactor Inspector,= Plant Date d[' Systems Section, Division of Reactor Safety > 2/22 /76 Approved: e 1. Barnes, Chief, Materials and Quality Date Programs Section, Division of Reactor Safety 9003140012 900308 ' PDR ADOCK 05000498 c.
g PDC
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-p .?. . . ..In.spection Summsrv . ^ Inspection Conducted lanuary 8-12 1990 j,R,eport 50- Q8/_90-Og 50-499/90-0?}
, u Areas Inspected: Routine, ennounced inspection of previous inspection _
findings, procurement program, comercial grede procerement and dedication i ' b _ ectivities, quality assurance program, and 10 CFR Part P1 progrem.
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- Results
- The licensee has established and implemented a program which, in general, meets the quality assurance description specified in the Updated Final
, Safety Analysis Report and the Technical Specifications. The requirements of ' 10 CFR Part 21 have, with the exception'of the identification of a noncited-I violation regarding the posting of an outdated copy of the regulation (paragraph 7, been appropriately implemented by the licenste.
i As e result of following up on a licensee identified condition related to the inverted, installation of electrical relays, a violation was identified (paragraph 3.2)regardingthefailuretoincorporatethedesignrequirements for seismic restraints on Class 1E electrical relays into installation instructions associated with modifications made to the emergency diesel generator cabinets.
, 'As a result of the violation identified in kRC Inspection Report 50 498/89-16; 50-499/89-16 - the licensee perforned a review of more than 2600 purchase orders (P0s),which had been issuej by HL&P. The review revealed some problems with respect to P0s and wrchase requisitions (prs) being. inconsistent regarding technical and. quality requirements; however, all of the discrepancies-l have been or are being resolved. This review also caused HL&P to recognize the l need for a program review, which resulted in procedure revisions, added
controls, and personnel' training.
' With respect-to comercial grade procurement and dedication activities, it was verified that the licensee has finalized a program which is consistent with l the guidance contained in EPRI NP-5652 and Generic Letter 89-02. An inspector followup item was identified pertaining to the results obtained by the licensee in its review of commercial grade procurements made prior to finalization of
- program requirements. Twoapparentviolationswereidentified(paragraph 5)
during review of procurement packages, involving the failure to have measures which would preclude the inadvertent use of incorrect parts, and the closing of a nonconformance report without performing the required corrective actions. An additional noncited violation was identified (paragraph 5) pertaining to the failure' to incorporate or reference an applicable procurement specification for sealed bearings into a PR.
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,_; " r + Ufb y 6s DETAILS ' , g i - > > , , C L -i.
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t1 ; PERSONS CONTACTED , , .
ItL&P - i '
.- < f% .*D.; P. ' Hall, Group.Vice President., 'i . y;gex
- J~. E. Geiger, General Manager, Nucitar Assurance
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- R.;W.'Chewning,1 Vice President, Nuclear Assurance
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- TsJ. Jordan; Manager,PlantEngineering l
' ', N; OT Green, Manager,.Huclear Quality Control t
- S. M. Dew, Manager,-Nuclear Purchasing Material Management
, '*S'. L~. Rosen, Vice President,. Nuclear Engineering and Construction !
- L. B. Horrigan, Jr.', Vice President, Purchasing and Support Services
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- W. H. Kinsey, Plant Manager
. - *A. C; McIntyre, Marager, Support. Engineering-Department (SED) . ' ' v'
- S. Timmaraju, Senio* Consulting Engineer, SED
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- C. A.~Ayala, Supervising Engineer, Licensing L*P. L. Walker, Senior Licensing Engineer
- J. T. Westermeier, General Manager, Administrative Support
. . 1*R. J. Tennant, Manager, Material Management t = *W.1J.-Jump, Maintenance Manager' . -*M. A.:McBurnett, Licensing Manager ,
- R. P. Garris, Director, Nuclear Purchasing and Contracts
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- D. WU Bohner, Quality Engineering Manager
" W.G.iWe11 born,' Manager,MaterialTechnicalServices(MTS)
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- M.:: F. Polishak, Supervisor. Material Parts List (MPL) Group, MTS -
' ', ' *N.J Patel, Supervising Engineer,MPL Development Group .
- P.'R.;Desai~, Quality Engineer, SED
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- J. W.1Crenshaw, Lead Electrical' Engineeri Construction
' ' ' *P; Newcomb,' Electrical. Engineer.
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- J.JE. Adkins; Staff Quality Assurance Specialist
' - *T..F. Walker; Lead Commercial Grade Procurement Group, MTS . J. Motichek, Lead.. Spare Parts Engineering D. E. Mathews, Spare Parts Supervisor, Nuclear Purchasing ', f - NRC:
- J.11.:Tapia', Senior Resident Inspector
. a The' inspectors also interviewed other licensee employees during the inspection.
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- Denotes' attendance at exit interview conducted on January 12, 1990.
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L,1,CENSEE ACTION ON PREVIOUSLY 1 DENT 1FIED ITEMS (92702) " 2.1 (Closed) Violation (498/8916-02;499/8916-02) This violation identified three instances in which the technical and/or quality .incorporatedinto.the.applicablepurchaseorders(P0s)(prs)werenot requirements established in the purchase requisitions that were issued to e ,. vendors.
> HL&P's comitted corrective actions included: revising the' applicable Nuclear . Purchasing and Materials Management procedures to include the requirement that > all safety-related and comercial grade procurement documents must be reviewed and verified prior to issuance using the newly developed Procurement Document
, Quality Checklist; providing training to the personnel responsible for conducting the.PR and P0 reviews; reviewing all previously issued HL&P P0s and their applicable prs to verify consistency and to correct any identified
discrepancies; and evaluating the impact of any identified discrepancies with respect _to material already received against those P0s.
The inspector verified that the committed corrective actions had been performed.
Refer to paragraph 4 for additional information regarding this violation and the , procurement program.
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FOLLOWUF (92701) .3.1-(Closed)UnresolydItem(489/8916-03L499/8916-03) , -This u'nresolved item pertained to the identification that the licensee was in ' the process of upgrading its procurement program requirements to address , commercial grade procurement practices.
During this inspection, the inspectors reviewed the comercial grade program i requirements contained in STP Specification No. 5A010WS0026, Revision 0, " Specification for Parts Classification and Comercial Grade Items Dedication in Safety Related Applications," and Procedure-IP-5.1Q, Revision 5 " Procurement of Items." The inspectors found from this review that the program-requirements appeared to be consistent with the guidance contained in EPRI-NP-5652, " Guideline for the Utilization of Comercial Grade Items in Nuclear Safety-Related Applications," and Generic Letter 89-02, " Actions to.
Improve the Detection of Counterfeit and Fraudulently Marketed Products." As a result.of completion of program requirements for commercial grade procurement,. L this unresolved item is considered closed.
The inspectors additionally ascertained that specific commercial grade items associated with the unresolved item (i.e., Square D 125 VDC relays) had been dispositioned by the licensee to be scrapped. As discussed in paragraph 5, the
licensee has instituted a program for the review of commercial crade procurements made prior to finalization of program requirements. This program l has not yet been completed. Review of the completed program results is considered an inspector followup item.
(498/9002-04;499/9002-04) .1
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. , . c ... . . L p L-5-e t [ 3.2I Installation of Electrical Relays-During this inspection, a followup was made regarding electrical relays which had been identified by the licensee during postmaintenance. surveillance testing as having been installed in an inverted position and, in one case, found to be o loose. These particular relays were located in the cabinet associated with , Emergency Diesel Generator (EDG) No. 22.
, . Licensee review has established that the inverted position does not have any affect on the operability of the relays. The inspectors noted, however, that
these particular relays are required to be seismically qualified.
Review of the - seismic qualification reports for this equipment revealed that the relays were- ' qualified with seismic retaining. clips attached. This raised a question with ,
respect to the seismic qualification of the one relay which was found in a loose condition.
, In order to obtain a better understanding of the possible reasons for this condition, the inspectors, with assistance of licensee personnel, aerformed a walkdown of the electrical relays associated with the EDGs for bot 1 units.
T During this walkdown, the inspectors noted that retaining clips were either missing or were not " locked" in place, thus allowing a potential loose condition to exist fn each of the' identified instances. The cabinets for Unit 1 EDGs 11, 12, and 13, each contained three relays with missing clips. Additionally, the , cabinet for EDG 13 contained 3 relays which had loose clips. The cabinets for Unit 2 EDGs 21 and 23 contained 2 relays and I relay, respectively, with loose clips. The cabinet for Unit ? EDG 22 contained one relay with a missing clip.
This failure to incorporate design requirements into installation instructions . to maintain seismic qualification (as specified in-the seismic qualification report) is an-apparent violation of Criterion III of Appendix B to 10 CFR Part 50.
(498/9002-01;499/9002-01) 4.
PROCUREMEN,T PROGRAM (38701) NRC. Inspection Report 50-498/89-16; 50-499/89-16 documented an inspection of the ? procurement arogram and the identification of a violation. At that time, it was determined tint additional inspection of program implementation would be required.
HL&P's connitted. corrective actions, as stated in paragraph 2.1 above, were extensive. Nuclear Purchasing and Materials Management Procedure NPMMP-4.7Q, " Preparation and Issuance of P0's/ Contracts and Supplements" was revised by Change Notice on July 31, 1989. The changes included the establishment of a Procurement. Document Quality Checklist (PDQC) and a Nuclear Contracts Checklist which became attachments to the procedure. The procedure now requires that the appropriate checklist be completed for all safety-related, quality related,. and commercial grade P0s, and their supplements. Completion of the PDQC is meant to show that a review of the P0 and the applicable PR was performed to verify that all technical and quality requirements are consistent. The buyer initieting the procurement action is responsible for the verification and is required to sign the PDQC.
In addition, the next higher level of authority must perform a separate verification. The completed PDQC with the two verification signatures
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.is to b'e filed in the procurement document file. All procurement personnel B received documented training pertaining to the content and use -of the checklists.
- All previously issued HL&P P0s :(approximately 2600) and,their applicable prs
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-were reviewed. 'This review resulted in the discovery of approximately 139 P0s ! ~ hich exhibited requirements that were not fully. consistent with the applicable i w prs and required-some degree of correction.
It was noted that the review
started with the most recently issued P0s and worked backwards to the oldest
. , PJ issued P0s. This resulted in the identificction of 24 discrepancies for the' L ~first 1800 P0s reviewed, and approximately 115 discrepancies in.the remaining-800 P0s. At the time of this inspection, all of the discrepancies had been
' reconciled except for 10 P0s. The remaining discrepancies'were scheduled to , have their evaluations. completed by January 15, 1990.
' + 'The inspector selected 20 P0s, including the 3 that were identified in the violation, to verify that reviews had been aerformed-(as shown by the existence of a PDQC in the procurement package) and tiat identified discrepancies had or were being resolved.
In. addition to the 3 P0s which were known to have been discrepant, 2 others in the group of 20 had exhibited some type of discrepancy.
- The discrepancies had been identified on the respective PDQCs and had been - resolved. The remaining 15 00s and their respective prs were shown on the PDQCs as being acceptable and were reviewed by the inspector to verify that the technical and quality requirements were consistent.
In each case where it was-determined by the licensee that a P0 revision was required. a supplement was transmitted to the affected vendor along with an acknowledgement form. The affected vendor was instructed to review the specified changes and indicate whether it could comply. For those items that had already been shipped, the . original submitted documents were required to be amended to indicate compliance with the new requirements. Where reconciliation between received items and specification requirements was not possible, a downgrade occurred.
It was also noted thatLdiscrepancies identified between the P0 and the PR did not necessarily-require a change to the P0. Evaluations verified that certain'P0s were correct and it was determined that the prs had to be corrected. This entire review L process was a coordinated effort which included the purchasing, engineeriug, L quality control, and quality assurance departments.
It would appear that with the implementation of the added controls to ensure l . consistency between prs and P0s regarding technical and quality requirements, L the procurement program has been considerably enhanced. No violations or ' deviations were identified in this area of the inspection.- -5.. COMMERCIAL GRADE PROCUREMENT AND DEDICATION ACTIVITIES (38703) As noted in paragraph 3.1, the licensee has finalized its program requirements.
for consnercial grade procurement and instituted a review of procurements made , prior'to completion of the program. A status of these review activities is L' , provided by the following information. HL&P contracted with IMPELL Corporation- ' to perform a review and evaluation of all CGI and nonsafety-related item
L procurements nade prior to August 11, 1989. All CGis and nonsafety-related i.tems' procured subsequent to August 11, 1989, would be evaluated by HL&P. The ' inclusionLof.nonsafety-related items was limited to those which could be used e , ) ~ ' t
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,- . in a-safety-related systen or component and was to provide assurance that the
- items were correctly designated as nonsafety-related.
IMPELL started in October , 1989, and it was anticipated that the effort would be completed at the end of ' _ ' January 1990. At the time of this inspection, a total of 4251 HL&P part numbers, , referred to as class / bins, have been identified as being within the scope of this effort. ' Of. this: number,1493: are CGIs and 2758 are nonsafety-related.
IMPELL'had completed their. review and evaluation of 42 CGIs. HL8P did not have = the actual'results in hand, but had been told _ by IMPELL that all 42 would require additional dedication activity. A review and evaluation had been completed on.978 nonsafety-related items and it had been determined that all but 130 had been designated correctly. The 130 that had been deemed as being incorrectly designated as nonsafety-related will_ require dedication. This activity had not yet been performed.
Discussions with licensee personnel raised two concerns: (a)itdidnotappear t" that any attempt had been made to determine the relative importance of installed j, CG!s in order to prioritize the order in which evaluations were to be conducted; ' and.(b) rather than placing a hold on CGIs in stock while this effort was ongoing, i the'11censee continued to permit the issuance of CGis without determining the
possible impact on operability if the item (s) were subsequently found to be j unacceptable.
! , , The licensee had established a Project Utilization of Haterial Program (PUMP) for transferringaitems which had been previously purchased during the construction
era tinto. the: current Hl.&P operations program. Only those items which-could be
considered for possible spare parts usage were included. Licensee perscanel stated d .thatPUMPwasstarted(intermsofactualmaterialtransfer)inOctober1988, -l ?and_ completed at,the end of 1989. All of the items which had been transferred ' prior;to-August 11, 1989, were included in the dati, base provided to IMPELL for
evaluation. HL&P was responsible for performing the evaluations of items ) . transferred after August 11, 1989. The licensee informed the inspectors that a ! - material issue hold had been placed on all items which had been transferred after August'11, 1989.
. Prior to this inspection, the inspectors requested HL&P to provide a computer
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printout which listed all CGIs procured for safety-related use. The primary
field'was based on class / bins. The inspectors selected a sample and requested ' L HL&P:to assemble the procurement packages, including all documentation pertaining i L yto the procurement and dedication activities. The inspectors reviewed the .j . assembled packages of 46 class / bins (7 of which were subsequently determined to L have actually been ordered as safety-related and, therefore, should not have
? .been on the list). The packages for 10 class / bins showed that the items had been purchased from the original equipment manufacturer or supplier, using the . original part numbers, drawings, and specifications, or by using procurement l-documents that required design compatibility with the originally supplied plant equipment. The inspectors did not observe.any problems with these packages.
Packages for six class / bins showed that the items were in some stage of procurement and had not yet been received. The packages for class / bins 588-1078 and -1079 showed that P0s had not yet been generated; however, review of the completed and approved PR for these items identified a failure to follow procurement procedures j ,,
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regarding the incorporation of all technical and qutlity requirements.
- Procedure NPit1P 4.120. Revision 1, required the responsible engineer to review the. items on a PR and assure that technical requirements which have been incorporated into an epproved togineering specification are either duplicated in the PR, or the engineering specification itself is referenced. PR 140908 dated
October 3,1989, showed that the items (sealed bearings) were being procured es CGIs'for use in safety-related charging pump's air supply fan motors, without specifying the required lubricant. The motors were qualified to 10 CFR Part 50.49 using only Chevron SRI-2 lubricant. The licensee's applicable procurement specificetion for these bearings (Non-tretellic Material Qualification Procedure 13, Revision 9, dated January 11,1989) was neither referenced nor incorporated into the PR, and it is Appendix C to this specification that requires the use of Chevron SRI-2. This is an apparent violation for failure to accomplish activities affecting quality in ectordance with a prescribed procedure; however, the violation is not being cited because it is of minor safety significance and irects the criteria specified in Section V.A. of the Enforcerent Policy.
The remaining 23 class / bins included 11 which were part cf the transferred material in the PUMP program and, as such, were being evaluated by IMPELL.
However, it was noted that documentation which would support dedication of these ites.s was nonexistent. Virtually no documentation was availeble for the last 12 class / bins which would support dedicetion. However, with respect to class / bins Elbows, tube},5/8 X 1/2-inch, Male) and -4572 (Elbows, Tube, 5/8 X 501-4563 ( 1/2-inch X Pipe, ftmale a problem was identified with respect to a possible comingling of nonsafety-related and safety-related items having the same class / bin numbers. P0 RS0006F90 through Supplement 1, dated July 29, 1988, was placed with Rawson & Company, Inc., for five cach of the two class / bin numbers.
They were ordered as CGls and nonsafety-related, with their end application designated for use in wide range gas monitors. The P0 also specified that the fittings were to be Parker-Hannifin part numbers. The applicable receiving inspection reports show that five each (four on one 11aterial Receiving Report andoneonanother)ofthe 501-45035 end five each of the 501-4570s were accepted based on receivirg a Certificate of Conformance from Rawson. The parts were then placed in stores, and subsequently four of each were issued for use in the wide range gas nonitoring systems, thus leaving a balance of one each renaining in stores. During mid-1989, a group called the Catalog Cleanup Group was established by liaterials Management for the purpose of consolidating class / bin numbers and catalog descriptions of like ittms.
It had been identified that certain like items had been assigned different class / bin numbers as a result of different applications, or that certain like items had different catalog descriptions, etc. In addition, items are also assigned Material Control Codes (MCCs) which provide a procurement level and a quality determination or level. Therefore, different class / bin numbers or catalog descriptions for like items could conceivably have different MCCs. At the time the identification or description of the above fittings were consolidated, the MCCs were also revised.
In this case, the MCCs were revised conservatively (i.e., the quelity determination or level no longer showed the items to be nonsafety-related, but ASME Code, SectionIII, Class 2). Therefore, when subsequent P0s were placed for the procurement of rore of these fittings, they were ordered to ASME Section III, Class 2 requirements. When these items were received and accepted they were l !
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. ! -9- , placed into stores such that they were comingled with the balance-of-stoct ' . which had been previously bought as nonsafety-related but, because of the
consolidation / revision to the class / bin numbers and/or MCCs, were now identified ! as safety-related and for use in ASME Section III, Class 2 applications. Thus, there would be nothing to preclude the issuance of the previously purchased nonsafety related items for safety-related applications.
It should be noted that HL&P, upon being notified of this condition, contacted Parker-Mannifin Corporation, the manufacturer of the fittings. HL&P provided information such es their P0 No., class / bin No., quantity, the Parker-Hannifin part number which was speufied on the P0, and the heat code which was stamped on the fittings and requested Parker to investigate and determine whether or not these fittings had been manufactured in accordance with their ASME quality program..On January 11,1990 Parker-Hannifin sent a Certificate of Compliance / Comormance, which attested to the fact that these fittings were banufactured in accordance with their ASME quality program authorized by ASME Quality Systems Certificate No. QSC 408.
In this particular case, it would appear that HL&P was fortunate in that Parker-Hannifin was able to provide substantiating documentation. However, existing administrative controls allowed this condition to occur and the possibility exists that it extends to other parts (i.e., commingling of nonsafety-related andsafety-relatedlikeitemshcvingthesameidentification). This failure to have ineasures which would preclude the inadvertent use of incorrect parts is an apparent violation of Criterion V111 of Appendix B to 10 CFR Part 50.
(498/9002-02; 499/9002-02) s Another problem was identified with resoect to class / bin 515-3007?. HL&P placed nonsafety-related P0 RS0000671, dated September P2, 1987, with Farmer's Copper and Industrial Supply, Inc., for 3 each,1-inch round stock in 11-foot lengths, i - of aluminum bronze ASTM 8150, CA630, for use in component a oling water heat exchangers(tubeplugg(ingapplication).Upon receipt of the material, Nonconformance Report NCR) RP7-92 was initiated because the meterial could not i be identified to an approved procurement document. The disposition stated that ' the material should have been procured as safety-related or evaluated by the use E
l of an On Site Certification (050).
It further stated that the evaluation had I been performed ant) documented on 05C-87-008; however, for added assurance, engineering ??d directed that a 1/P-inch test specimen be cut from each rod in order to on. we the material for its key elements. The disposition also stated that Certified Material Test Reports (CMTRs) had been received which show the material to be in compliance with the material specification. The Disposition Results/ Action Taken section showed that the hold tags had been removed because the material had been processed per the NCR disposition and 05C-87-008. The NCR was then closed out with the appropriate signatures. Review of 050-87-008 revealed that additional testing was required, and it stated that prior to the , installation of tube plugs, a specimen must be taken from each rod and analyzed i - to verify that the key elements are within the acceptable range of the material specification. HL&P personnel stated that this material had been issued and installed. The inspectors requested to review the test results in order to verify that they had been performed as required. HL&P personnel could not - - - - - --
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' provide any documentation which would substantiate that these tests had been performed. Review by the Senior Residtnt Inspector confirmed that testing was ! initiated by the licensee subsequent to the inspection in response to the ' ' inspectors' id(ntification of this problein. Closing of the NCR without performing the required actions stated in the disaosition is an apparent i - violetion of Criterion XVI of Appendix B to 10 CFR Part 50, which requires that ,.
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identified nonconformances be corrected.
(498/900?-03;499/9002-03) 6.
QUALITY ASSURANCE PROGRAK ANNU,A,L, REVIEW _(35701) - 6.1 Quality Assurance Program Chanjes L Inordertoassessthecurrentqualityassurance(QA) program,theinspector selected the 11 QA procedures listed in the Attachrnent for review of the changes r which had been made since the previous NRC inspection of the QA program. The ! r changes to the procedures wcre revised for conferinance with the approved QA C program description in the Updated final Sefety Analysis Report (UfSAR) and the Technical Specifications (TS). The significance of the changes, including organizational and personnel changes, were discussed with the QA manager who was
responsible for making changes to the program description, as well as the impleinenting procedures.
In general, the changes to the 0A impleraenting procedures were timely and consistent with the UFSAR and TS.
No violations er deviations were identified during this area of the inspection.
6.2 QA Program Imp,1,epentation , The isnplementation of the QA program has been previously addressed in the areas of the records program, document control progratr, audit program, tudit program implernentation, and receipt, storage, and handling of equipinent and materials program (seeNRCInspectionReports 50-498/89-16; 50-499/89-16 and 50-498/89-20;50-499/89-20). The inspection of the QA program implarentation in the area of the procurement program is discussed in paragraph 4 ebove.
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10 CFR PART 21 INS,P,E,C, TION (36100) To assess implementation of the 10 CFR Part 21 regulations, the inspector first - verified that the licensee had established procedures to irtplernent the i i requirements of 10 CFR Part 21 by reviewing the following interdepartraental p.
procedures.
IP-1.03Q, " Reporting 10 CFR 21 Deficiencies To The NRC," Revision 1
L IP-1.62, " Bulletin Boards and Postings," Revision 0
IP-1.450, " Station Problem Reporting," Revision 4
IP-1.8Q, " Control of Vendor Documents," Revision 7 " These procedures provide satisfactory instructions to all departnents within the i licensee's organization for reporting defects, posting, evaluating deviations, , l . >
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. l-11-informing the responsible officer, informing the NRC, spesifying procurement requirernents, maintenance requirements, and disposition of records.
I; ext, the inspector selected three problem reports in order to review the licensee's process of identifying problem and then evaluating them for " reportability. The first problem report was identified as PR-890177 and , consisted of a potential interference associated with certain strut / snubber assemblies. The second problem report was identified as PR-890243 and consisted ! of a generic problem with certain naterial used in the plugging of steam gcnerator tubes. The third problem report was identified as PR-890379 and , consisted of a potential generic problem with degradation of certain current " , transformers over a long period of exposure to high temperature / humidity. The ! inspector concurred with the licensee's conclusion that the condition or defect described in each of these problem reports was not reportable.
The specification of the application of 10 CFR Part 21 provisions in applicable procurement documents was included as part of the rcview of procurement documents discussed in paragreih 4 above. The procurement documents reviewed specified, when appropriate, t1at 10 CFR Part 21 was applicable to the items-being purchased.
The inspector selected ? of the 14 bulletin board locations listed in Procedure IP-1.62 for verification of the posting requirements specified in 10 CFR Part 21. The two locations selected were the Administration Building and Building 15 which is the Nuclear Assurance Building.
Both bulletin boards contained a copy of the Part 21 regulations, a copy of Section 206 of the Er.ergy Reorganization Act of 1974, and a notice which states whom to contact or call for examining the procedures applicable to 10 CFR Part 21. However, the copy of 10 CFR Part 21 posted on both bulletin boards was determined by the inspector to be several years outdated. The failure to post a copy of the current Part El regulations is a apparent violation of 10 CFR Part 21.6. The licensee took the necessary action to post the current copy of Part 21 on the bulletin boards.
The licensee also initiated action to ensure on a quarterly basis that the current copy of-the Part 21 regulations is the one posted on the bulletin boards. Therefore, this violation is not being cited because the criteria of Section V.A. of the NRC's Enfor:ement Policy have been met.
8.
EX1T_)f(TERVIEW (30703) An exit interview was held on January 12, 1990, at the conclusion of this inspection, with the personnel denoted in paragraph 1.
At the exit interview, the inspectors summarized the inspection findings. No information was presented to the inspectors that was identified by the licensee as being proprietary.
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- - -' A1TACHMENT
'.' List of QA Prog _ ram _ Procedure Changes Reviewed l o _ ' i.
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' Procedure QAP-1,1, " Organization and Responsibilities," Revision 2 ! Procedure QAP-1.2, " Procedure Development," Ret sion 3 ,
Procedure _ QAP-1.4, " Indoctrination sod training of Personnel," Revision 2 f-Procedure QAP-1.5 " Vendor Deficiency Reports," Revision 4 ! t , l Procedure QAP-1.6, "Procurenent of Items and Services," Revision 2 l Procedure QAP-2.1, "Trainirg, Qualification and Certification of Audit i Personnel," Revision 2-j r Procedure QAP-2.2, " Training, Qualification and Certification of Surveillance _ Personnel." Revision 2 { f Procedure QAP-2.3, " Operational QA Trend Analysis," Revision 4 l g ' Procedure QAP-2.4, *QE Evaluation of Vendors," Revision 3 l , Procedure QAP-2.8, " Plant and Vendor Audits," Revision 2 i Procedure QAP-2.9, " Plant Surve111 onces," Revision 5
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