ML19225B005
| ML19225B005 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1979 |
| From: | Brown R, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19225A995 | List: |
| References | |
| REF-QA-99900401 99900401-79-2, NUDOCS 7907230308 | |
| Download: ML19225B005 (25) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900401/79-02 Program No. 51100 Company:
Combustion Engineering, Inc.
1000 Prospect Hill Road Windsor, Connecticut 06095 Inspectica Conducted: April 23-27, 1979 Inspectors:
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k_/ M hh-7 h R. H. gklev, Princip'aD Inspector, Vendor Date Inspection Bracch sh 5
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J. R. M tello, Principal] Inspector, Vendor Date Inspection Branch 3's la o [V 5-9-79 R. L.
pwn,'PrincipalInpector, Vendor Date Insp tion Branch l
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Approved by:
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h C. J. Hal Q, hi6f, Vendor Program Evaluation Date Sectioc, Vendor Inspection Branch Summary Inspection conducted on April 23-27, 1979 (99900401/79-02)
Areas Inspected:
Implementation of the Ccmbustion Engineering QA Program in the areas of design input, design inspection, procurement source selection, suppller nonconformance and corrective action, and follow-up on previous inspection findings. The inspectica involved eighty-four (84) inspector-hours on-site by three (3) NRC inspectors.
Results:
In the five (5) areas inspected, there were no unresolved items identified in any of the areas, no deviations identiiied in four (4) of the areas, and two (2) deviations identified in the i.emaining area.
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2 Deviations:
Follow-up on previous inspection findings - some audit reports were not dated as required by procedure QAP 18.1, and contrary to proce-dure QAP 16.1, two (2) different corrective action reports were assigned the same identification number.
A13 13%o
3 DetailsSection I (Prepared by R. H. Brickley)
A.
Persons Contacted G. C. Beshoff, Engineer J. D. Boyajean, Senior Engineer P. H. Hepner, Supervisor, Safeguards Systems
- D. M. Mayer, Supervisor, Planning and Procedures C. M. Molnar, Senior Engineer
- Denotes those present at the exit interview.
B.
Design Inspection - Containment Spray System 1.
Objectives The objectives of this area of the inspection were to verify for the containment spray system that:
Design criteria, requirements and commitments, as listed a.
in the SAR, were utilized in design input during system and component design.
b.
Analyses of containment pump net positive suction head (NPSH) during' all phases of operation follow the guidance of Regulatory Guide 1.1.
c.
Design analyses establish the capability of the system to provide flow at rates and temperature which result in heat removal rates consistent with those utilized in the LOCA and/or main steam line break analyses.
d.
Specifications and/or procurement documents for system components require them to be designed, fabricated, erected, and tested in accordance with applicable ASME Section III and 10 CFR 50, Appendix B, requirements.
e.
Provisions and plans have been made for pre-operational and operational testing consistent with SAR commitments and statements.
f.
The analysis (design) of system spray coverage supports SAR commitments and statements.
b,ff f
4 g.
The system design for pH control including analyses of pH versus time after system actuation supports SAR commit-ments and statements.
h.
Provisions to prevent trapp ng of chemical additives implement SAR commitments.
i.
Calculations of iodine removal constants, use parameters, and system characteristics are consistent with those in items a-h, above.
j.
Iodine removal constants used in the analyses of the radiological consequences of a LOCA are censistent with item i., above.
2.
Method of Accomplishment The preceding objectives were accomplished by and examination of:
a.
Sections 6.2.2 (Containment Heat Removal Systems) and 6.2.3 (Containment Air Purification and Cleanups - Iodine Removal System) of Appendix 6B to Project No. 14273 PSAR, and Appendices 6A (Containment Spray System Licensing Report) and 6B (Iodine Removal System) to the System 80 CESSAR-FSAR for the technical commitments.
b.
Quality Assurance of Design Procedure Nos. 5.2 (Design Analysis), Revision 3, dated April 2, 1979, and 5.4 (Design Verification), Revision 1, dated December 29, 1978, for the procedural requirements.
c.
SYS 80-PE-SE (Plant Enginaering and Plant Apparatus Scope of Engineering for the System 80 Standard Design), Revision 01, dated June 9, 1977; SYS ^9-PE-DR 33 (Design Requirements -
Iodine Removal System for Sy;cem 80), Revision 00, dated October 25,1977; 14273-PE-DR 33 (Design Requirements -
Iodine Removal System), Revision 00, dated October 2, 1978; SYS 80-PE-DR 32 (Design Requirements - Containment Spray System for System 80), Revision 00, dated October 25, 1977; and 14273-PE-DR 32 (Design Requirements - Containment Spray System), Revision 00, dated October 2, 1978, to verify that they satisfied B.I.a., above.
d.
System Description Nos. SYS 80-PE-SD 33 (Iodine Removal for System 80 Standard Design), Revision 00, dated May 26, 1977; 14273-PE-SD 33 (Iodine Removal for ANFP), Revision 01, 413 132 H 13 a+
5 dated January 31, 1978; SYS 80-PE-SD 32 (Containment Spray System for System 80), Revision 00, January 31, 1977; and 14273-PE-DR 32 (Containment Spcay System for ANP), Revision 00, January 31, 1978, to verify that they satisfy B.I.a.
and B.2.c., above.
Specification Nos. SYS 80-PE-410 (Specification for Standard e.
Plant for Safeguard Pumps for System 80 Standard Design),
Revision 03, dated December 19,1977; 14273-PE-410 (Project Specification for Safeguard Pumps for ANFP), Revision 02, dated October 27, 1978; SYS 80-PE-605 (Standard Specifica-tion for ASME Section III Code Tanks for Sysum 80 Standard Design), Revision 02, dated April 7, 1977; and 14273-PE-605 (Project Spacification for ASME Section III Code Tanks for ANPP), Revision 05, dated June 16, 1973, te verify that they satisfy B.I.d. and B.2.c., above.
f.
Calculation No. V-PEC-018 (Containment Spray Pump Evalua-tion), dated February 21, 1976, to verify that it satisfied B.1.b., above.
g.
Calculation No. 14273-LOCA-008 (Arizona Containment Study),
dated May 5, 1978, to verify that it satisfied B.1.c., above.
h.
Calculation No. V-PEC-064 (Containment Spray Area Coverage at Operating Floor), dated April 7,1977, to verify that it satisfied,B.1.f., above.
i.
Calculation No. V-PEC-075 (2-hr Dose Reduction Factor Analysis), dated June 24, 1977, to verify that it satisfied B.1.i., above.
j.
Calculation No. V-PEC-072 (System 80 Iodine Removal System Component Design Requirements -
N,, H, System), Revision 00, dated June 1, 1977, to verify that it satisfied B.I.a. and the applicable documents of B.2.c., above.
3.
Findings a.
There were no deviations or unresolved iteas identified in this area of the inspection.
b.
The examination of calculation V-PEC-018 (Containment Spray Pump Evaluation) revealed two (2) minor calculational errors (Pg 13-Req, Pg 15-Hr ) and one (1) error in listing the term of an equation i.e. on page 21, the term E in the H 3
m 413 133
6 calculation should have been Eg (Note: The value for E had been used). Discussions with CE indicated that these 7
errors had no significant effect on the results obtained.
It should be noted that this calculation haa been independently reviewed without these errors being identified.
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C.
Exit Interview An exit interview was held with management representatives cn April 27, 1979. In addition to those individuals indicated by an asterisk in paragraph A of each Details Section, those in attendance were:
G. P. Allocca, Supervisor, Group Quality Systems M. R..Etheridge, Vice President, General Services E. P. Flynn, Director, Plant Apparatus and Engineering Quality Assurance (EQA)
F. G. Harvey, EQA C. W. Hoffman, Director, Group Quality Assurance The inspector summarized the scope and findings of the inspection.
Management comments were generally for clarification only, or acknowledgement cf the statements by the inspector.
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7 DetailsSection II (Prepared by J. R. Costello)
A.
Persons Contacted D. F. Benner, Senior Engineer Piping C. J. Bogacz, Mechanical Supervisor, Group Quality Control
- B. R. Davis, Manager, Group Quality Systems S. W. Denker, Manager, Network Planning C. Ferguson, Project Manager, Arizona Project W. J. Fitzpatrick, Lead Engineer, Primary Systems Components R. C. Gross, Assistant Project Manager
- G. J. Huba, Manager Engineering Quality Assurance J. C. Matthews, Supervisor, Primary Systems Components Group R. A. Mudgett, Cognizant Engineer W. Dilipski, Senior Nuclear Engineer J. G. Reik, Supervisor, Application Engineering D. L. Sigler, Application Engineer K. C. Tolides, QA Engineer
- Denotes those present at Exit Meeting.
B.
Follow-up on Previous Inspection Findings 1.
(Closed) Deviation (Report Number 78-02):
Contrary to commit-meats, management audits prescribed in Paragraph 17.2.6 of CENPD-210-A are not documented through written operating proce-dures; consequently, the control and execution of these audits are not performed consistently.
In Combustion Engineering's letter of response dated August 23, 1978, CE committed to develop a written procedure to control management audits by January 1979.
Procedure QSI-18.1, " Management Audit of QA Program," was issued on January 20, 1979.
2.
(Closed) Deviation (Report Number 78-03):
Contrary to 10 CFR 50, Appe-dix B, Criterion III, and implementing procedure PE QA Numter 001, the transmittal sheet for an unreviewed document did not indicate when the document would be reviewed.
The inspector verified that the current issue of Project Specifica-tion 14273 PE-410, Revision 2, has been verified; the transmitted document for Revision 2 has the requested signatures and dates; and a memo was issued on November 21, 1978, to all personnel in the affected group their to indicate on the trans-mittal document when unverified documents are to be verified.
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8 3.
(Closed) Deviation (Report Number 73-04): Contrary to 10 CFR 50, Appendix B, Criterion V, procedures do not exist for the evalua-tion and reporting of significant changes in the evaluation model as referenced in Section II of 10 CFR 50, Appendix K.
Quality Assurance of Design Procedure QADP 5.2 was revised on April 2, 1979, to include instructions for the evaluation and reporting of significant changes in the evaluation model.
4.
(Closed) Deviation (Report Number 79-01): Contrary to 10 CFR 50, Appendix B, Criterion V, and implementing procedure QAP 18.1 three (3) of the six (6) audit reports for internal audits con-ducted in 1978, were not published thirty (30) days after the post audit conference. The inspector verified that the corrective and preventive action described in Combustion Engineering's letter dated March 5, 1979, has been completed.
In particular, the three internal audit reports cited were published in January 1979; a method for tracking and close-out of internal audits has been instituted; and the Compliance Supervisor has been authorized to requisition manpower from other sections to perform the necessary audits.
5.
(Closed) Deviation - Contrary to 10 CFR 50, Appendix B, Criterion V, and implementing procedure QAP 16.1, Corrective Action Request (CAR) QC-CAR-78-017, dated April 18, 1978, with a reply due date of May 8,1978, had not been responded to by the vendor on January 11, 1979, nor had a new CAR been generated. The inspector verified that the corrective and preventive action described in Combustion Engineering's letter dated March 5, 1979, has been completed.
In particular, a response to QC-CAR-78-017, dated January 24, 1979, was trasmitted on March 2, 1979. This response was reviewed and dispositioned by Group Quality Control. Also, GQC management have instructed responsible personnel in writing to review the CAR log on a montly basis. CAR's requiring a response during the subsequent thirty (30) day period are to be " flagged" and reported to the cognizant GQC representative for follow-up action.
6.
(Closed) Unresolved Item (Report Number 78-02): No internal audits are being conducted by either EQA or GQS personnel relative to the activities of Licensing and Project Management personnel in the Ccemercial Department.
It was determined by the inspector that no significant quality affecting activities are performed by these organizations at the present time. Also, the quality affecting activities they are involved in can be audited, e.g.
interface activities, when other organizations are audited.
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9 7.
(0 pen) Unresolved Item (Report Number 78-02):
It is not clear whether ANSI N45.2.6 is applicable to surveillance personnel.
CE has revised QAP 2.1, Appendix A, removing all references to ANSI N45.2.6.
However, Topical Report CENPD-210-A, Section 17.10, states that PSG Windsor personnel performing surveillance activities are qualified to ANSI N45.2.6-1973, whereas Table 17-3 of CENPD-210-A states that this standard is not applicable to the surveillance personnel organization (5072-Group QA). This matter will remain open until the conflict of requirements in the Topical Report and CEs interpretation of these requirements are resolved.
8.
(Closed) Unresolved Item (Report No. 78-04): Verification has not been completed on two (2) calculations which resulted in input to the CESSAR System 80 FSAR. This item will continue to be considered unresolved until NRR/NRC has completed their review to determine what constitutes " final analysis" for purposes of FSAR submittals.
9.
(Closed) Items For Consideration By CE Management (Report No. 78-04):
a.
NRC Item:
There does not appear to be any central index to define what constitutes the code design file, or a project design file.
Discussion:
This is a central index which defines what constitutes the code design file and the project design file. The index is maintained by a quality records controller who is responsible for issuing unique log numbers based on the type of calcula-tion. This indexing system is described in Quality Assurance of Design Procedure-QADP 5.2, DESIGN ANALYSIS.
Recommendation:
This indexing system has been found to be sufficient to control documentation and no change to the current procedure is recommended.
b.
NRC Item:
Procedure do not address how modifications to NRC-approved codec are reported to NRC.
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11 Discussion:
The approved evaluation model codes contain models or correlations which have been compared to test data.
These comparisons are documented in the topical reports describing the CE evaluation model.
CE does use test data, as available e.g. through the Standard Problem Program, to develop and evaluate CE's Best Estimate LOCA Model.
Recommendation:
No changes to the present method of code verification is recommended.
e.
NRC Item:
On the "ECCS Licensing Analysis Verificatioa Checklist,"
Item 25 was checked "yes," indicating experimental data was employed. No evidence of how the experimental data was employed was found.
Discussion:
In the System 80 CEFLASH-4A calculational input file provided to the NRC for review Item 25 was checked "yes."
Experimental data is used in generating the licensing models described in CENPD-132 (Calculative Methods for the CE Large Break LOCA Evaluation Model). Since the ECCS analyses have to comply with the models documented in CEXPD-123, it appears unnecessary to suppl 3 further evidence of how the experimental data was employed.
Recommendation:
No change to current practices is recommended.
f.
NRC Item:
Procedures do not address how errors identified in codes are dispositioned.
Discussion:
The QADM (Quality Assurance of Design Manual) requires that errors detected during QA be resolved between the 1
413 1 395
12 originator and the independent reviewer.
If resolution of the problem cannot be attained at this level, then successive levels of management shall become involved until the disagreement can be resolved to everyone's satisfaction. This procedure clearly indicates the path to be followed when a deficiency is uncovered. Along with the new statement to be included in the QADM (see Item 2), regarding reporting modifications to NRC approved codes, sufficient procedures are available which address the disposition of deficiencies in codes, calculations, or components.
Recommendation:
No change to current practices is recommended.
g.
NRC Item:
A chronological listing of development, review, approval, and changes to codes had not been documented.
Discussign:
A chronological listing of the path a code follows exits implicitly via the manner in which code versions are identified.
In addition, each document describing new code versions contains a list of references which provides the above information.
Recommendation:
Since the present documcatation practices permit the tracking of the development path of a code, no changes are recommended.
h.
NRC Item:
Procedures do not exist for detailing the process to be followed when existing codes are used in new applications.
Discussion:
Procedures do exist in QAEM (Quality Assurance of Design Manual), which address the process to be followed when a new or revised standard analysis method is to be implemented in design analy is.
These procedures are discussed in QADP 5.2, Design Analysis.
413 J 3j}
13 Recommendation:
No changes in procedures are recommended.
i.
NRC Item:
(1) Documentation of comparison of codes 'ith previous results is not being maintained.
Discussion:
Documentation of comparison of codes with previous results is maintained since the NRC approval process fer new ECCS codes results in a comparison between the new code and previous codes. This informatica is also submitted to NRC.
Recommendation:
No changes to present practices are rectemended.
(2) NRC Item:
Documentation of the review of QA folders for codea is not being maintained.
Discussion:
The code design files for the codes have to satisfy QADM (Quality Assurance of Design hanual), require-ments and, thus, are signed by the originator and independent reviewer to indicate that review has taken place.
Recommendation Since documentation of review of QA folders for codes is proveided by the reviewer's signature, no changes to current procedures are recommended.
(3) NRC Item:
Documentation is not being maintained which addre. cd why a change to a code is being made.
(Lf 413 tsi3)
14 Discussion:
The documentation of all ECCS code versions explicitly describes the reasons for any code changes. This documentation is necessary in order to describe the developmental path of a code and is typically provided in the topical report documenting new code versions.
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Recommendation:
No change in present practices are recommended.
J.
h7C Item:
Departmental level procedures for code development, review, approval, and control do not exist.
Discussion:
The QADM (Quality Assurance of Design Manual) was created with the objective of bringing all QA procedures into one manual which could be used throughout Nuclear Power Systems.
One reason for doing this was to eliminate the proliferation of departmental level procedures and, thus, assure a uniform approach to Quality Assurance.
Recommendation:
To maintain the integrity of the QADM as the sole QA document to be adhered to, creation of a new departmental procedure is not recommended.
k.
NRC It m:
CESSAR/FSAR/ System 80 LOCA Analyses were submitted to NRC prior to the completion of independent review of the analyses. QA review and verification of all documents should be completed prior to submittal to hTC.
Discussion:
Item 11 constitutes the " Unresolved Item" mentioned in the NRC Audit Report. According to the NRC Audit Report the resolution of this item is being pursued by the NRC internally.
CE will defer comment on this item until this review is complete.
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15 1.
NRC Item Procedures do not address how individual codes are to be used in an overall analysis model or package.
Also, there are no requirements for assuring that integral results developed from more than one code are independently reviewed.
Discussion:
CENPD-132 explicitly details how the ECCS codes are to be used for large break LOCAs, while CENPD-137 provides similar informatica for the analysis of the small break LOCAs.
Intergral results developed from more than one code are quality-assured as per QADM and, thus, independently reviewed.
Recommendation:
Since both dotiments (CENPD-132 and CENPD-137) have received NRC :pproval, no additional procedures are considered necessary.
10.
Findings In this area of the inspection, two (2) deviations were identified.
(See Notice of Deviation enclosure, items A and B).
C.
Design Inputs 1.
Objectives The objectives of this area of the inspection was to determine that:
a.
- rocedures nave been established and are being implemented that prescribe the system for control of those criteria, parameters, bases, or other design requirements upon which detailed final design is based.
b.
Design inputs are specified on a timely basis, their selection reviewed and approved, incorporated into the design documents, and changes in input are justified, reviewed, and approved.
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16 c.
Commitments are properly translated into design inputs, as applicable to the following:
(1) Basic functions (2) Performance requirements (3) Regulatory requirements, codes, and standards (4) Design conditions (5) Loads (6) Environmental conditions.
d.
I:esign requirements are specified, when applicable, relating to interfaces, materials, mechanical, structural, hydraulic, chemistry, electrical, instrumentation and control, redun-dan g, accessibility, fire protection, and other requirements.
2.
Methods of Accomplishment The preceding objectives were accomplished by an examination of:
a.
Comtustion Engineering, Inc., Topical Report CENPD-210-A, Revision 3, Section 3 ' Design Control), which establishes present QA Program commitments.
b.
Chapter 17.1 (Quality Assurance) of CESSAR Amendment No. 12, Section 3 (Design Control), which established QA Program commitments prior to the Topical Report (circa 1973-1975).
c.
Quality Assurance of Design (QADP) procedures to assure that procedural controls had been provided to satisfy QA commit-ments and to satisfy Items (a) through (d) of the Objectives Section above. These procedures are listed below:
(1) QADP 5.0, " Design Process," Revision 0, dated May 3, 1976.
(2) QADP 5.1, " Design Input," Revision 0, dated May 3,1976.
(3) QADP 5.2, " Design Analysis," Revision 2, dated June 6, 1977.
8 [ )'
142
17 (4) QADP 5.3, "Inte;rface Control," Revision 0, dated May 3, 1976.
(5) QADP 5.4, " Design Verification," Revision I, dated December 29, 1978.
(6) QADP 5.5, " Preparation, Control, and Retention of Drawings," Revision 1, dated February 21, 1977.
(7) QADP 5.6, "?rocedures For The Preparation and Quality Assurance af Specifications," Revision 2, dated May 6, 1977.
(8) QADP 5.11, " Stress Reports," Revision 0, dated February 1, 1978.
d.
Documents to verify implementation of program commitments and procedural requirements and to satisfy implementation of Items (a) through (d) of the Objectives Section. These documents are as follows:
(1) Specification No.1370-PE-705, Revision 2, Project Specification For Nuclear Service Motor Operated Valves.
(2) Specification No. 00000-PE-140, Revision 4, General Specification For Reactor Coolant Pipe and Fittings.
(3) Specification SYS 80-PE-CR10, Revision 0, Component Design Requirements For Reactor Coolant System For System 80 - Standard Plant.
(4) Calculation PS-100, January 23, 1976, Tentative Sizing Calculation of The Reactor Coolant Pipe and Elbows.
(5) Calculation PS-200, February 22, 1976, Tentative Sizing Calculation of The Piping Nozzles.
(6) Report No. CENC-1365, March 19,1979, Analytical Report For Southern California Edison San Onofre Unit No. 2 Piping.
(7) Specification No. 1370-ICE-3017, Revision 2, Project Engineering Specification For Vital Bus Power Supply System.
(8) Specification No. 00000-ICE-3017, Revision 1, General Engineering Specification For Vital Bus Power Supply System.
k
18 (9) Specification No. 1370-ICE-3004, Revision 1, Project Engineering Specification For Core Protection Calcu-lator System.
(10) Specification No. 00000-ICE-3004, Revisica 3, Engineering Specification For Core Protection Calculator System.
(11) Specification No. 1370-ICE-3006, Revision 2, Project Engineering Specification For An Ex-Core Neutron Flux Monitoring System.
(12) Specification No. 00000-ICE-3006, Revision 3, CENPD Engineering Specification For Ex-Core Neutron Flux Monitoring System Specification.
(13) Specification No. 1370-PE-515, Revision 2, Project Specification For A Reactor Coolant Pump Motor Hydraulic Snubber.
(14) Specification No. 00000-PE-504, Revision 0, General Specification For Reactor Coolant Component Hydraulic Snubber.
(15) Specification No. 1370-ICE-3008, Revision 1, Project Engineering Specification For Reactor Trip Circuit Breaker Switchgear.
(16) Specification No. 00000-ICE-3008, Revision 1, General Engineering Specification For Reactor Trip Circuit Breake Switchgear.
3.
Findings In this area of inspection, no deviations from commitment or unresolved items were identified.
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19 DetailsSection III (Prepared by Ross L. Brown)
A.
Persons Contacted C. J. Bogacz, Supervisor, Group Quality Control (GQC) (Mechanical)
- E. F. Boudreau, Supervisor, Group Quality Systems G. A. Brucker, Supervisor, GQC (ICE)
G. S. Brunetto, Supervisor, GQC (Plants and Sites)
- Attended exit meeting.
B.
Procurement Source Selection 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for the selection of qualified suppliers of services, materials, parts, and components that provide for:
a.
Requirements for evaluation of the potential supplier's capability to provide items or services in accordance with the technical and quality assurance specifications of the procurement documents.
b.
Methods of evaluating potential suppliers that are consistent with applicable regulatory, code and contract requirements, and should include source evaluation audits, review of historical performance, and/or review and evaluation of the supplier's QA Program, manual, and procedures.
c.
Consideration of the complexity, inspectability and safety significance of purchased items or services when selecting the method of source evaluation.
d.
Performance of source evaluation audits that include appropriate checklists or instructions for systematic review of the prospective supplier's QA system.
e.
Qualification requirements for personnel performing source evaluation audits.
f.
Source selection being based on his orical product performance that includes review of past procurement and operating 413 146
20 experience with identical or similar items and is limited to relatively simple services or off-the.-shelf items.
g.
Periodic re-evaluation of suppliers and that an up-to-date listing of the evaluation status is being maintained.
h.
Distribution of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to companies designated in these documents.
i.
Measures to assure that the supplier's bid conforms to the procurement document requirements and that resolution of unacceptable conditions identified during bid evaluation are corrected before the contract award.
2.
Methods of Accomplishment The preceding objectives were accomplished by examination of:
a.
Combustion Engineering, Inc., Topical Repot CENPD-210, Revision 3 (Topical Report), Paragraph 17.7.1, requires a technical and quality evaluation of suppliers.
Paragraph 17.18 requires periodic audits to assess the supplier's maintenance of, and compliance to, the applicable quality system.
b.
Group Quality Assurance Manual (GQAM), Procedure QAP 4.1, which requires the Group Quality Control (GQC) Representa-tive review the requisitions to assure that the vendor is on the Approved Vendor List (AVL) for the type and quality class of equipment being procured.
GQAM, Procedure QAP 7.1, describes the procedure which c.
applies to the evaluation of suppliers to the applicable programmatic requirements and facility survey (initial and resurveys) to assure that the suppliers' practices and supporting documentation are in conformance with his QA Program and procurement requirements, including off-the-shelf and spare or replacement parts.
d.
GQAM, Procedure QAP 7.2, describes the method for Vendor Approval by Product (items which are normally stocked as catolog or standard off-the-shelf items or subvendors of original equipment) by engineering, procurement and GQC.
413 14Gl
21 GQAM, Procedure QAP 18.2, establishes a procedure for e.
selecting, conducting, and reporting of in process audits that are normally conducted by the GQC Representative during routine surveillance visits. These audits of QA Program elements are performed to assure continued conformance with his program.
f.
Vendor Quality Control Program Specification WQC 11.1, Revision D.
This document is included in the procurement package (when required by specification or contract) and outlines the minimum quality requirements which shall be met by the vendors of equipment to which it is applied.
g.
The following Group Quality Control (GQC) record to verify implementation of the procedural requirements described in B.2.a, b, c, d, e, and f.
(1)
Purchase Order No. 9500945 for Plant Prctection System (PPS), (CE contract 9270), and the following associated documents; (a) Evaluation Survey Reports for years 1973, 1975, 1977, and 1978.
(b) Audit Reports (mini) for years 1976, 1977, 1978, and 1979.
(c) Three (3) Surveillance Reports.
(d) One Certificate of Equipment.
(2) Purchase Order No. 9501431 for Reactor Trip Circuit Breaker Switchgear (CE contract 1370) and the following allied records; (a) Evaluation Survey Report.
(b) Audit Reports (mini) for 1977 and 1978.
(c) Two (2) Surveillance Reports.
(d) Two - ) Certificate of Equipment.
(3) Purchase Order No. 9402051 for Paenumatic Operated Valves (Class 1, 2, and 3), (CE contract 1470), and the following associated records; 413 1 41s
~
22 (a) General Engineering Specification For Nuclear Service Valves No. 00000-PE-707.
(b) Evaluation Survey Report.
(c) Surveillance Reports Nos. I through 31.
(d) Vendor Audit Reports (mini) for 1973 and 1979.
(e) Two (2) Certificates of Equipment.
(3) Purchase Order No. 9772026 for Seal Injection Heat Exchangers (CE contract 14273) and the following related records; (a) Evaluation Survey Report.
(b) Four (4) mini audit reports.
(4) Purchase Order No. 9602008 for Reactor Coolant Pump Motor Hydraulic Snubber (CE contract 8973) and the following associated records; (a) Evaluation :;urvey Report.
(b) Two (2) mini audit reports.
h.
Personnel Qualification Records (written examinations, eye examinations and management certification) for three (3) auditor /QC Representatives.
3.
Findings In this area of the inspection, no deviations from commitments or unresolved items were identified.
C.
Supplier Nonconformance and Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that w.ocedures have been established and implemented for:
Disposition of nonconformances that provide for:
a.
(1) Measures by the purchaser and supplier for identifica-tion, control, review, and disposition of items or 4/3
/@
23 services that do not meet procurement document requirements.
(2) Submittal of noncomformance notice to purchaser by supplier which shall include recommended disposition and technical justification.
(3) Submittal to the purchaser for approval of dispositions containing one o. more of the following nonconformances:
(a) Technical or material requirement violated.
(b) Violated requirement in supplier document approved by purchaser.
(c) Nonconformance cannot be corrected by continuation of the original process or by rework.
(d) Original requirement is not met but the item can be restored so that its function is not impaired.
(4) Purchaser disposition of supplier recommendations, verification of disposition, and maintenance of records of nonconformance.
b.
Corrective action that provides for:
(1) Identification of and timely corrective action for conditions adver;e to quality which occur during the procurement process that are the responsibility of the purchaser.
(2) Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
(3) Reporting these conditions and the corrective action to management.
(4) Assuring that corrective action is implemented and maintained.
(5) Verification of supplier's corrective action system.
/b 413 kg
24 2.
Methods of Accomplishment The preceding objectives were accomplished by examination of:
a.
Topical Report, Paragraph 17.15, that requires all Power Systems Group (PSG) supplier and manufacturing facilities to employ a written system for identifying documenting, and controlling items which do not conform to contract require-ments to prevent their inadvertent use.
Paragraph 17.16 also requires all PSG suppliers and manufacturing facilities to have a system to assure that conditions adverse to quality are identified, documented, and corrected. For significar.t conditions adverse to quality, measures must be implemented tc assure that the cause of the condition is determined and corrective action is taken to prevent recurrence. Also, significant condi-tions must be reported to the appropriate levels of manage-ment.
b.
GQAM, Procedure QAP 15.2, provides a method and designates the responsibility for the processing and review of the Deviation of Contract Pequirements (DCR).
c.
GQAM, Procedure QAP 16.1, provides instructions for the initiation and follow-up requirements in the use of the Corrective Action Report (CAR) and reporting to the appropriate level of management.
d.
Quality Assurance of Design Procedure QADP 6.3 describes the purpose of a DCR that provides a means for formalizing the description of nonconforming conditions and for requesting acceptance of material or services which do not agree with procurement requirements.
e.
GQAM, Procedure QAP 10.1, establishes the method of selecting GQC witness / hold points and provides requirements and guidelines for planning, performance, and documentation of verification activities.
f.
Vendor Quality Control Program Specification 00000-WQC 11.1, Revision D; (1) Paragraph 5.2.8, requires the vendor to have a written system to identify, document, control and disposition nonconforming materials.
~4/3
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25 (2) Paragraph 5.2.9 requires in case of significant condition adverse to quality, measures shall be implemented by the vendor to assure that the cause is determined and the corrective action taken is to be documented, evaluated and reported to appropriate levels of management.
g.
The vendor DCRs submitted to CE relative to the following purchase orders (PO) to verify implementation of the above requirements; (1) Three (3) DCRs issued against P0 No. 9500945.
(2) Two (2) DCRs issued against PO No. 9772026.
h.
Corrective Action Reports (CARS) initiated by CE-GQC related to the following P0s to determine conformance with the above requirements; (1) One Ct.R related to PO No. 9500945.
(2) Two (2) CARS related to P0 No. 9402051.
(3) Three (3) CARS related to P0 No. 9772026.
3.
Findings In this area of the inspection, no deviations frca commitments or unresolved items were identified.
/S'.:L 413 tiSil memomy
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