ML17083B590
| ML17083B590 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/08/1985 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML17083B591 | List: |
| References | |
| NUDOCS 8505300495 | |
| Download: ML17083B590 (10) | |
See also: IR 05000275/1985016
Text
Docket Nos. 50-275,
50-323
Pacific
Gas
and Electric Company
77 Beale Street,
Room
1451
San Francisco,
94106
glory 081985
Attention: J.
D. Shiffer, Vice President
Nuclear Power Generation,
Licensing
Subject:
NRC Inspection of Diablo Canyon Units
1 and
2
This refers to the special inspection
conducted
by Messrs.
D. B. Pereira
and
T. Crowley of this office during the period of March 25 through April 26,
1985, of activities authorized
by NRC License
No. DPR-76 and Construction
Permit No. CPPR-69.
Areas
examined during this inspection are described in the enclosed
inspection
report.
Within these
areas,
the inspection consisted of selective
examinations of procedures
and representative
records,
interviews with
personnel,
and observations
by the inspector.
No violations with NRC requirements
'were identified within the scope of this
inspection.
In accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosure
will be placed in the
NRC 'Public Document
Room.
Should you have any questions
concerning this inspection,
we will be glad to
discuss
them with you.
Sincerely,
CHgIn"l sf-~c:P by
Q. F~ KIrsch
D. F. Kxrsch, Acting Director
actor Safety
& Projects
Dxvxszon of Re
Enclosure:
l.
Inspection Report Nos. 50-275/85-16,
50-323/85-16
2.
PG&E Letter No. DCL-85-15-2
3.
PG&E Letter No. DCL-85-153
cc w/enclosure:
Jim Knight, NRR;
S.
D. Skidmore,
P. A. Crane
(PG&E)
R.
C. Thornberry
(PG&E - Diablo Canyon)
D. Taggart
(PG&E - Diablo Canyon)
R. Weinberg
(PG&E - Diablo Canyon)
Sandra Silver
State of CA
bcc:
gSB/Document. Control Desk (RIDS); Mr. Martin; Resident Inspector;
LFMB
PZRHKA/dot
DO
H
KITH
5/f /85
5 g/85
5/g/85
Diablo Canyon
SSER-33
iB.4-1
Appendix B
8505300495
850508
ADOCK 05000275
9
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-275/85-16
and 50-323/85-16
Docket Nos. 50-275
and 50-323
License No. DPR-76
Construction Permit No.
CPPR-69
Licensee:
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Facility Name:
Diablo Canyon Units
1 and 2
Inspection at:
Diablo Canyon Site,
San Luis Obispo County, California
Inspection
co
Inspectors:
Approved by:
cted
Mar h 25 through April 26,
1985
1
n gMt.
. B. Pereira,
Reactor Inspector
T. Crowley, Reactor
ns ector
R. T. Dodds, Chief, Reactor Projects
Section
8
D
e
igned
s
PS
Da
e
igned
~ 7A-
1
Dat
igned
~Summa a:
Ins ection from March 25 throu h A ril 26
1985
(Re ort Nos. 50-275/85-16
and
50-323/85-16
involved 86 inspection hours by two inspectors.
Results:
No violations or deviations
were identified.
Diablo Canyon
SSER-33
B.4-2
Appendix B
DETAILS
1.
Persons
Contacted
M. Tresler, Project Engineer Assistant,
S.
M. Skidmore,
Manager, Quality Assurance,
D. Aaron, Quality Assurance
Engineer,
P.
G. Dahan, Quality Control .Engineer,
J. Brattois, Special Projects,
R. Hobgood, Supervisor, Quality Control,
K. A. Nilson, Field Engineer,
H. Karner,
Manager, Quality Assurance/Quality
Control, Pullman Power
Products
NOTE:
The allegation characterization
statements
contained in this
report are
a paraphrasing
of the staff's understanding
of the allegers
concern based
upon copies of their affidavits and other documents
submitted by allegers.
The characterization
statements
do not represent
a staff assessment,
conclusion or position.
2.
Alle ation or Concern Nos.
1664
1668
1673
1674
1675
1676 and
1677
ATS:
RV-85A-0999
Characterization
Pullman Power Products'iscrepancy
Report 89173 (12-21-84)
does not
provide for a system of identification, documentation,
segregation
and
disposition of Cardinal materials previously purchased
and installed by
Pullman in both units of the Diablo Canyon Nuclear Plant.
This is
a
nonconformance
to 10 CFR 50 Appendix
B criteria
XV - Nonconforming
Materials, Parts or Components
and Criteria XVI - Corrective Action.
Pullman DR/I9173 only provides for a system of identification and
documentation for material in Pullman's warehouse/storage
areas
which
were manufactured
by Cardinal.
PG&E does not provide
a system of identification, documentation
and
segregation
of Cardinal materials previously purchased
and installed by
Pullman in the plant.
Nonconformance
to 10 CFR 50, Appendix B, Criteria
XV and XVI.
do not specifically provide for a system of
identification, documentation
and segregation
of all Cardinal materials
previously purchased
and installed by Pullman in the plant.
Nonconformance
to
10 CFR 50, Appendix B, Criteria XV and XVI.
Failure by PG&E/Pullman's
DR/I9173 to address/identify,
document
and
segregate
Cardinal materials previously purchased
and installed by
Pullman in the plant is
a significant condition adverse
to quality.
Diablo Canyon
SSER-33
B.4-3
Appendix B
Cardinal materials'uality is indeterminate for material purchased prior
to 1-9-84.
PG&E conveniently ignored findings on Cardinal's
QA program until well
after any licensing impact.
Im lied Si nificance to Desi n
Construction
or 0 eration
Pullman has purchased
and installed Cardinal bolts
and fasteners
at the
Diablo Canyon Nuclear Plant since
1977.
Since Cardinal's past Quality
Assurance
Program
has
been identified by the
NRC and
PG&E to have
significant deficiencies
making the quality of their material
indeterminate,
this material could result in an inability of safety
systems
to perform their intended safety functions.
Assessment
of Safet
Si nificance
Back round
On June
29,
1984, the
NRC issued Information Notice No. 84-52,
"Inadequate Material Procurement
Controls
on the Part of Licensees
and
Vendors" to inform licensees
of deficient procurement controls
and
quality assurance
(QA) practices
on the part of suppliers of nuclear
materials
and to call attention to possible generic problems in
procurement activities of licensees.
The Information Notice stated that
a large
number of quality-related deficiencies
on the part of nuclear
suppliers
was revealed in the
NRC inspections.
One of these nuclear
suppliers,
Cardinal Industrial Products
Corp.,
was suspected
of deficient
procurement
controls
and
QA practices.
As a result,
PG&E conducted
an audit of Cardinal Industrial Products
on
December 6-7,
1984 and January 3-4,
1985, in Las Vegas,
Nevada.
The
purpose of the audit was to determine if they had adequately
implemented
their quality assurance
program for materials Cardinal supplied to the
~Diablo Canyon Power Plant.
The audit found that there
was insufficient
documented
evidence
to support the adequate
implementation of Cardinal'
quality assurance
program.
Cardinal
was
removed from the
PG&E Qualified Supplier's List on September
28,
1984, after PG&E's review of the
NRC inspection of Cardinal.
Per
PG&E's request,
Pullman Power Products
issued Discrepancy Report
(DR)
/39173 on December
21,
1984 which placed all material in Pullman's
warehouse
which was manufactured
by Cardinal Industrial Products
Corporation
on hold.
This
DR disposition included listing all Cardinal
manufactured
items currently in stock, identifying all items currently
ordered
from Cardinal but not yet received,
segregating
and retaining
a
minimum of four items of each size
and heat
number for possible future
testing,
and issuing instructions for conditionally releasing
items
placed
on hold pursuant to PG&E's authorization in their letter to
Pullman dated
December
21,
1984.
This action was approved
by the
Technical Review Group
(TRG) on January
21,
1985 in accordance
with
section
10.1 of the
PG&E Quality Assurance
Program.
Diablo Canyon
SSER-33
B.4-4
Appendix B
The alleger
has stated that the Pullman Power Products
DR/j9173 does not
provide for a system of identification, documentation,
segregation
and
disposition of Cardinal materials previously purchased
and installed by
Pullman in both units of the Diablo Canyon Nuclear Plant,
and is
applicable only for material manufactured
by Cardinal.
The alleger
has
stated that
PGSE
and
PGSE Quality Assurance
instructions
do not
specifically provide for a system of identification, documentation
and
segregation
of Cardinal materials previously purchased
and installed by
Pullman in the plant.
According to 'the alleger, this is
a nonconformance
to
10 CFR 50, Appendix B, Criteria XV and XVI.
In addition,
the alleger
states
that failure by PGGE/Pullman
DRN9173 to address/identify,
document
and segregate
Cardinal materials previously purchased
and installed by
Pullman in the plant is
a significant condition adverse
to quality.
The
alleger states
that Cardinal materials'uality is indeterminate for
material purchased prior to 1-9-84.
Staff Findin s
The problem area in question
and selected
records of PGSE and Pullman
Power Products
were examined
and assessed
by the inspectors.
The
inspectors
examined
these allegations with the intent of evaluating
whether licensee
management
had acted in a responsible
manner in their
assessments
and conclusions,
and determining whether any technical
question
remains unresolved.
Cardinal Industrial products
has developed
and is currently implementing
an extensive action plan for revalidati,on of materials
supplied to the
nuclear industry that has
been reviewed
and approved
by the NRC's Vendor
Program Branch.
The approved
program includes documentation/
certification verification, physical
and chemical analysis verification
tests of selected lots of material,
and an extensive
vendor validation
and monitoring program to ensure
purchase
order requirements
have been
passed
down through the channel to the subcontractor(s).
The sampling
plan basis will provide
a 95/ confidence level for each product category
supplied through each "channel" (i.e. includes all contractors
down to
the
raw material producer).
The licensee
has determined that they and their contractors, principally
Pullman,
have received
197 purchase
orders consisting of 943 line items
from Cardinal.
Attached to this report is
PG&E letter No. DCL-85-153
which is
a status
report of the Cardinal revalidation program as it
applies to Diablo Canyon.
Any identified discrepancies
resulting from
the revalidation program are being dealt with (located
and segregated
as
appropriate)
in accordance
with the licensee's,
QA program for
"Nonconformances
and Corrective Actions," Procedure
10.1.
The
ASME SA material certification review program has been completed.
The
certification review for other than
ASME material
was
90$ complete.
The
results of the reviews to date
have disclosed that appropriate
documentation is in place for materials
reviewed with one exception
pertaining to forty-eight A193 studs
and A194 nuts supplied to Vnit 2 for
the main .steam line isolation valves.
In this case,
material
traceability was lost on the studs during the forming process,
and the
nuts
had been purchased
from an unapproved
source.
Diablo Canyon
SSER-33
B.4-5
, Appendix
B
The inspector verified that the discrepant
studs
and nuts had been
located
and replaced with acceptable
material in accordance
with the
program.
The licensee
has tested
these
studs
and nuts
and determined
that they meet the required material specifications
and, therefore,
would
have performed
as designed
had not the discrepancy
been identified.
Staff Position
The staff concludes that
PGSZ has
a
QA program inplace for controlling
nonconforming material
and that this program
was followed in the
identification and segregation
of material in stock and in the
dispositioning of the one instance
where the
NRC approved Cardinal
revalidation program identified potential discrepant material.
This
series, of allegations is considered
closed.
None.
3.
Alle ation or Concern
Nos.
1666
1665
and
1667
ATS:
RV-85A-0999
Characterization
Pullman Power Products'endor
Quality system audit of Cardinal did not
address
heat treating of material
as required.
Pullman's
Vendor Quality system audit program for Cardinal is in
nonconformance
to ASME Section III, NCA-3820, a, b, and
c (1980 Edition)
and
10 CFR 50 Appendix
B Criteria VII - Control of Purchased
Material,
Equipment,
and Services.
Cardinal appears
to have
had no quality system program covering heat
treating of material during 1981.
Im lied Si nificance to Plant Desi
n
Construction
or 0 eration
Incorrect or nonexistant
heat treatment of Cardinal material purchased
for Diablo Canyon Nuclear Plant
may result in the quality of the material
to be indeterminate,
thus resulting in an inability of safety systems
to
perform their intended safety functions.
Assessment
of Safet
Si nificance
Back round
The alleger has stated that Pullman Power Products'endor
quality system
audit of Cardinal did not address
heat treating of materials.
Specifically, checklist item I/18 - verify if heat treating is performed
in accordance
with approved procedures
- is marked not applicable
and no
audit was performed.
Checklist items //19, 820,
II21 and kj29c having
similar heat treatment
requirements
were also marked not applicable
and
no audit was performed.
The alleger
has stated that Pullman's
Vendor
Diablo Canyon
SSER-33
Appendix
B
Quality System Audit program for Cardinal is in nonconformance
to ASME
Section III, NCA-3820 a, b,
and
c (1980 Edition) and
10 CFR 50 Appendix
B
Criteria VII, since Pullman did not audit the heat treatment of fasteners
manufactured
and/or supplied by Cardinal.
The alleger has stated that
this is a significant condition adverse
to quality.
The alleger
has
stated that Cardinal appears
to have
had no Quality System Program
covering heating treating of material during this time period.
Staff Findin s
The subject of heat treating was examined
and assessed
by the inspectors.
The subject
was also discussed
with licensee
personnel.
The inspectors
verified that Cardinal did not perform heat treating of materials,
but
rather
had Precision
Heat Treating
Company perform the heat treatment
before
1981.
As a consequence
there
was no Cardinal Heat treatment
program and the audit checklist items 818, jjl9, jI20, j/21, and jj29c were
correct in being marked not applicable.
The first time Cardinal
performed in house heat treatment for Diablo Canyon material
was February
21,
1983.
There
was
no prior in house heat treatment
used
on Diablo
Canyon or Pullman materials.
Therefore,
heat treating records for
Pullman orders were, in fact, not auditable at the Cardinal facility.
The alleger's interpretation is incorrect concerning Pullman's
Vendor
Quality System Audit program for Cardinal per
ASME Section III, NCA-3820
a, b,
and
c and
10 CFR 50 Appendix
B Criteria VII, since Pullman
conducted audits of Cardinal's Quality Assurance
program.
Cardinal
conducted
a system of planned
and documented
external audits performed to
verify compliance with all aspects
of the suppliers
and suppliers of
subcontracted
services
(such
as heat treatment).
Cardinal conducted
Q.A.
surveys of Precision Heat Treating on 8/25/78~
8/27/79~ 7/3/8lj 12/6/82,
and 12/1/83 by C.W. Eliason.
All audits
and surveys
by Cardinal found
Precision Heat Treating acceptable.
Pullman's audit revealed that
Cardinal's Quality Assurance
Manual, Section
8 performs audits of
external suppliers of subcontracted
services.
Even through Cardinal had
no heat treatment
program,
the Cardinal audits of Precision Heat Treating
verified that the material
was properly prepared
and had quality
documentation for shipment to Pullman.
Therefore,
there is no deficiency
in the
1980 and
1981 audits of Cardinal with respect, to heat treating
and
no non-conformance
to ASME Section III NCA or 10 CFR 50, Appendix B.
Staff Position
The staff concludes that this allegation is not valid based
on both
Pullman's
and Cardinal's audits.
There is no requirement for Pullman to
conduct
an audit of Precision Heat Treating.
Cardinal's prior audits of
their heat treatment supplier indicated satisfactory results
and no trend
towards poorer quality was indicated.
These allegations
are closed.
No
violations or deviations
were identified.
Action Re uired
None
4.
Alle ation or Concern Nos.
1669
1670
1671
and
1672
Diablo Canyon
SSER-33
B.4-7
Appendix
B
ATS:
RV-85A-0999
Characterization
Pullman's
Vendor Quality System Audit did not list and no audit was
performed to determine if the person or department
responsible for
defining and implementing the overall effectiveness
of the quality
program reported regularly on the effectiveness
of the program.
Pullman's
Vendor Quality System Audit failed to check Cardinal employees
who performed functions within the scope of ASME Section III to determine
if they were qualified to perform their duties in 1981.
Pullman's
1981 audit of Cardinal did not audit to see if nondestructive
examinations
(NDE) were performed in accordance
with approved procedures.
Pullman's
1981 audit of Cardinal 'did not audit major portions of the
quality system program,
as required;
Im lied Si nificance to Plant Desi n
Construction
or 0 eration
The overall effectiveness
of the quality assurance
program needs
to be
reported to ensure material, procedural,
and operational
requirements
are
met on
a continuing basis.
Only qualified Cardinal employees
who perform functions within the scope
of ASME Section III should perform those functions.
NDEs need to be
performed in accordance
with approved procedures.
Assessment
of Safet
Si nificance
The alleger
has stated that Pullman's audit did not list or determine
the
person or department
responsible for defining and implementing the
overall effectiveness
of the program.
The alleger further states
the
Pullman audit failed to check Cardinal employees
who performed functions
within the scope of ASME Section III to determine if they were qualified
to perform such duties.
Pullman's audit failed to determine if NDE's
were performed in accordance
with approved procedures.
In addition,
Pullman's audit of Cardinal did not audit major portions of the quality
system program,
as required.
The in'spectors
examined the
1981 Pullman's audit of Cardinal
and assessed
the alleger's
findings of Pullman's audit deficiencies.
The inspectors verified that Pullman's audit did determine that
Cardinal's Quality Assurance
Manual, Section
3 had the necessary
items
implemented to define and implement the overall effectiveness
of the
program.
The items listed were that the person
was designated
in
writing, independent
from production pressures,
and had direct access
to
management.
Diablo Canyon
SSER-33
B.4-8
Appendix B
The audit finding code
was satisfactory.
Cardinal's Quality Assurance
Manual, Section
3 satisfied
the audit evaluation step.
The staff
disagrees
with the alleger,
since Cardinal's
QA manual,
section
3 listed
the person or department
responsible for defining and implementing the
overall effectiveness
of the program.
Pullman's audit did list the
individuals or department,
but only quoted Section
3 of the Q.A. Manual.
The alleger is correct in his statement
that no Cardinal employee
who
performed functions within the scope of ASME Section III were audited to
determine if they were qualified as specified by Section III.
However,
no Cardinal personnel
performed
NDE, and no special processes
were
performed by Cardinal.
The audit by Pullman clearly states
that
NDE is
performed by Eagle Intermountain Testing and Eagle Intermountain
personnel
are listed.
Pullman's
1981 audit of Cardinal
was correct in not auditing to see if
NDEs were performed in accordance
with approved prcoedures.
Cardinal
has
a Quality Assurance
manual,
Section
8 which verifies that subcontractors
(Eagle Intermountain Testing)
have
QA programs.
The staff found that the Pullman
1981 audit was quite detailed
and
involved every major activity that Cardinal performed.
It simply did not
audit those
items that Cardinal did not perform but that had to be
subcontracted,
such
as heat treating
and
NDE.
Staff Position
The staff concludes
that the allegations
are not valid based
on both
Pullman's
and Cardinal's audit findings.
Pullman's
1981 audit was
extensive
and examined
every activity that Cardinal performed.
Pullman
did not audit the subcontractor
that Cardinal
was using for heat
treatment
and
NDE.
These allegations
are closed.
No violations or
deviations
were identified.
Action Re uired
None.
Diablo Canyon
SSER-33
B.4-9
Appendix
B
I