ML19263B674
| ML19263B674 | |
| Person / Time | |
|---|---|
| Issue date: | 07/19/1978 |
| From: | Costello J, Haley C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263B662 | List: |
| References | |
| REF-QA-99900401 99900401-78-2, NUDOCS 7901220356 | |
| Download: ML19263B674 (23) | |
Text
.
VEtlDOR ItlSPECTI0tt REPORT U.S. flCCLEAR REGULATORY COMMISS10tl 0FFICE OF IflSPECTI0tl AtiD EilFORCEMEilT REGI0tl IV Report flo.
99900401/78-02 Program flo. 44081 Company: Combustion Engineering, Inc.
1000 Prospect Hill Road Windsor, Connecticut 06095 Inspection Conducted: June 27-30, 1978 Inspectors: hh.OM 7//9b?
. CostElio, Principal Inspector, Vendor Date '
spection Branch W (M -
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J.(/M. Jorson, Contractor Auditor, Vendor Date Inspection Branch
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C. J. Ha4e, Chief, Projects Section, Vendor Date Inspection Branch b
Acoroved by:
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f C.' J. 'Hafe, Chief, Projects Section, Vendor Date Inspection Branch Summary
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IInspection~on_ June 27-30, 1978_(99900401/78-02).
Areas Inscected.
Implementation of the Combustion Engineering QA program in the areas of evaluation of supplier performance, verification activities, product acceptance, audits, and action on previous inspection findings.
The inspection involved eighty-one (31) hours on site by three (3)
USilRC inspectors.
7901220 356
. Results:
In M,e five (5) areas inspected, si; (6) deviations were identifiec in four (4) of the areas and three (3) unresolved items were identified in two (2) of the areas.
Deviations:
(1) Audits - Contrary to CE Topical Report CENPD-210-A, one individual had performed audits of ilDE processes when his NDE qualifi-cation had expired (Notice of Deviation enclosure item A).
(2) Aualts -
Contrary to CE Topical Report CENPD-210-A, the system for r.anagement audits is not docurrented through written operating procedures (Notice of Deviation enclosure item B). (3) Audits - Contrary to CE Topical Report CENPD-210-A, Group Quality Systems is not fully implementing the CE internal audit program (Notice of Jeviation enclosure item C).
(4)
Verification Activities - Contrary to 10 CFR 50, Appendix B, Criterion III, the design of HPSI (High Pressure Safety Injection) header valves appears inadequate (Notice of Deviation enclosure item D).
(5) Evaluation of Supplier Performance - Contrary to 10 CFR 50, Appendix B, Criterion XV, no Field Action Report was generated for HPSI valves (Notice of Deviation enclosure item E.).
(6) Evaluation of Si oplier Conformance - Contrary to 10 CFR 50, Appendix B, Criterion V, eqcipn:nt with incomplete records were released for shipment without proper occumented approvals (Notice of Deviation enclosure item F).
Unresolved Items:
(1) Audits - No internal audits are being conduct _d by eitner EQA or GQS personnel relative to the activities of Licensing and Project Management personnel in the Connercial Department (DetailsSection II, paragraph C.3.c.).
(2) Audits - It is not clear whether ANSI N45.2.6 is applicable to surveillance personnel (DetailsSection II, paragraph C.3.d.).
(3) Product Acceptance - It is not clear whethe' Intergrated Manufacturing Quality Plans (IMQPs) are being approved six weeks prior to fabrication (DetailsSection I, paragraph B.3.).
DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted
- C. J. Bogacz, Mechanical Supervisort Group Quality Control
- E. F. Boudreau, I.C.E. Supervisor, Group Quality Control.
G. S. Brunetto, Plants & Sites Supervisor, Group Quality Control J. M. Burger, Supervisor, Fuel and Control Element Assembly Design
- G. J. Huba, Manager, Nuclear Engineering Quality Assurance F. N. King, Senior QA Engineer, Contract Quality Assurance D. R. Knauff, Supervisor, Contract Quality Assurance R. T. Kunze, Head Engineer, Group Quality Con trol
- B. L. Riggs, Planning Supervisor, Group Quality Systems
- Denotes those present at exit meeting.
B.
Product Acceptance 1.
Objectives The objectives of this area of the inspection were to verify that procedures had been established and implemented that provide for:
a.
Requiring supplier verification of compliance with procurement requirements prior to offering the product (item or service) for acceptance.
b.
Documentary evidence that items conform to purchase docu-ments be available at the nuclear facility site prior to installation or use of the item, when applicable.
Verification of documents certifying conformance which meet the following minimum criteria:
(1)
Identification of the product and the procurement requ' ements met.
(2)
Identification of crocurement requirements not met with an. explanation.and i.aans. for resolving the nonconformances.
.. ' :: et a v.u -..
.1,. g. r,. y s,-
(3) Attestatierr by responsible person whose function and position are described in the QA Program.
. (4) Description of certification system is contained in the QA Program.
d.
Methods used to accept an item or service from a supplier, such as source verification for items difficult to verify after delivery, receiving inspection for items which
~
are simple and standard, Supplier Certificate of Conformance for items that do not involve direct inspectica by the purchaser, post installation test at the site if the item must be installed to verify its quality character-istics, and when services only are involved, technical verification of data produced and/or review of objective evidence of conformance to procurement document require-ments.
2.
Method of Accomolishment The preceding objectives were accomplished by a review of:
a.
Combustion Engineering's Topical Report CENPD-210-A and Chapter 17.1 of CESSAR which establishes program
~
commitments including:
(lj Product acceptance requirements and assignment of primary acceptance responsibilities.
These are described in Sections 17.7 and 17.1.7, Control of Pc chaseo Material, Equipment and Services.
(2) Primary functions and interface responsibilities between Combustion Engineering organizations and Combustion Engineering and their vendors. These are described in Sections 17.1 and 17.1.1, Organization.
(3)
Identification of applicable procedures and instruc-tions used to implement the program commitments.
These are described in Sections 17.2 and 17.1.2, Quality Assurance Program.
b.
Implementing procedures to satisfy program commitments and satisfy items (a) through (d) of the Objectives Section above, including:
.:(1). Quality i Assurance of Design Procedures (QADPs)
<2.. : v.
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i
! 1 I
5.0 Design Process 5.6 Procedures For the Preparation and Quality Assurance of Specifications 6.0 Procurement Control 6.1 Request for Approval or Review (RAR) 6.2 Technical Change Request (TCR) 6.3 Deviation from Contract Requirement (DCR)
(2) Group Quality Assurance Procedures (QAPs) 3.1 Submittal Instructions for Technical Change Request (TCR) 4.1 Procurement Document Control 5.2 Review of Customer Bid Specifications for Nuclear i
Steam Supply System (NSSS) and Fuel 5.3 Review of Contracts 6.2 Submittal Instructions for Request for Approval or Review (RAR) 7.1 Vendor Evaluation 7.2 Vendor Selection 7.3 Review of Vendor's Procedures 8.1 Certification of Equipment 15.1 Submittal Instructions for Deviation of Contract Requirements (DCR) 15.2 Review of Deviations of Control Requirements (DCR) c.
Special generic documents used to satisfy program commit-ments:
Specification 00000 '4QC 11.1, Vendor Quality Control Program Specification, and Approved Vendor List.
d.
Documents to verify implementation of program commitments and procedural requirements and to satisfy implementation of items (a) through (d) of the Objectives Section above.
Documents were selected by randomly picking existing purchase or manufacturing orders and reviewing the pertinent documents related to the purchase or manufacturing
.... ~ _.
-.a
.. orders, such as. project specifications, general specifications,..
.. if Tcir:.'~iq :'m i dntergrate~dimanufacturing quality plans (IMQPs), certi--
w.m c. fi.catiom of equipmen'c, surveillance reports, requests -for t.
r.'
- :.approvalcor. review (RARs), technical change-requests (TCRs),
. x and deviations; from control requirements (DCRs).
u
These documents were revieved for evidence of conformance to purchase or manufacturing orders, adequacy of requirements in purchase and manufacturing orders and adequacy of methods used to verify product acceptance.
The purchase and manufacturing orders, with their supporting documentation.
that were reviewed, are as follows:
(1) Purchase Order P0-9301430-9270 to Unit Electric Control, Inc., for Reactor Trip Circuit Breaker Switchgear for Louisiana Power & Light Co. project, defined by Project Specification 9270-ICE-3008.
(2) Purchase Order P0-9501431-1370 to Unit Electric Control, Inc., for Reactor Trip Circuit Breaker Switchgear for Southern California Edison project, defined by Project Specification 1370-ICE-3008.
(3) Purchase Order P0-9601490-9270 to Reliance Electric Company for Auxiliary Protective Cabinet for Louisiana Power & Light project, defined by Project Specification 9270-ICE-3019.
(4) Purchase Order P0-9601489-1370 to Reliance Electric Company for Auxiliary Protective Cabinets for Southern California Edison project, defined by Project Speci-fication 1370-ICE-3019.
(5) Purchase Order P0-9501156-9270 to Bentley fievada Corporation for Reactor Coolant Pump Shaft Speed Sensing System for Louisiana Power & Light project, defined by Project Specification 9270-ICE-6003.
(6) Furchase Order P0-9500367-1370 to Bentley fievada Corporation for Reactor Coolant Pump Shaft Sensing System for Southern California Edison project, defined by Project Specification 1370-ICE-6003.
(7) Purchase order PO-9403340-9270 to Rosemont Engineering Compey for Instrumentation and Contrcl Equipment for Louisiana Power & Light project, defined by project specification 9270-ICE-0005.
M.%.,.
. n30-(87 i Purchaset Ord r:PO-9403339-1370 to Rosemont' Engineering
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Company for. Instrumentation and Control Equipment
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for-Southern Cali.fornia Edison project, defined by 1
Project Specification 1370-ICE-0005.
(9) Manufacturing Order M0-9630594 for Fuel Bundle Assembly Reload Drawing flumber E-8067-701-201.
Standard Engineering Specifications 00000-FCD-0100.
(10) Purchase Order PO-9601012-14273 to Dresser Industries, hc., Industrial Valve and Instrument Division, 'for Pressurizer and Main Steam Safety Valves for Arizona project, defined by Project Specification 14273-PE-701.
(11) Maufacturing Orders MP-9330905/06/07-14273 to P. F. Avery for Reactor Vessel Core Support and Internal Structure for Arizona project (Units 1, 2, & 3), defined by Project Specification 14273-RCE-0400.
(12) Purchase Order P0-9402483-1370 to Gould Pumps, Inc.,
for Spray Chemical Addition Pumps for Southern California Edison project, defir-d by Project Specification 1370-PE-404.
(13) Purchase Order P0-9301808-6370 to Rosemont Engineering Company for Instrumentation and Control Equipment for Arkansas Power & Light project, defined by Project Specification 6370-ICE-903.
(14) Manufacturing Orders M0-9330756/60/64-14273 to Chattanooga iluclear Operations for Reactor Vessel Assembly for Arizona Project (Units 1, 2, & 3),
defined by Project Specification 14273-PE-110.
(15) Purchase Order P0-9600978-3072 to Gaulin Corporation for Reciprocating Charging Pumps for Boston Edison project defined by Project Specification 3072-PE-403.
3.
Findinas There were no deviations identified in this area. One unresolved item was identified as follows:
Section 6.2 of the Vendor Quality Control Program Specification WQC 11.1 states in part, "The IMQP (Integrated Manufacturing o, -
c.,
- Quality Planbsha.ll be submitted to CE for review and-approval
- and ' incorporation.of. quality surveillance points..
c-
- -Submittal shal
- 1 tbe made as. required by the contract but-at c-a-
leas.t six (6)' weeks prior to release for fabrication." ~
P0 9403340-9270 was issued to Rosemont Engineering Corporation on April 3,1975, with a revision 2 issued on October 31, 1977.
This purchase order was for Instrumentation and Contract equipment cov3 ring resistance temperatunt detectors, thermowells, a.nd pressure transmitters.
Pressure transmitters have been shiped and an IMQP for the pressure transmitters has been submitted. However, no IMQP's had been submitted for temperature detectors or thermowells and it was not obvious that they weuld be submitted six (6) weeks prior to fabrica-tion of these items.
~
C.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on June 30, 1978.
In addition to the individuals indicated by a asterisk in the Details Sections those in attendance were:
B. R. Davis, Manager, Group Quality Control M. A. Burgan, Manager, Startup Quality Assurance and Quality Assurance Records E. P. Flynn, Director, Plant Apparatus and Engineering Quality Assurance T. R. Swif t, Manager, Contract Quality Assurance The inspector sumarized the scope and findings of the inspection for those present at the meeting. Management representatives acknowledged the statements of the inspector and made the following comments relative to the deviation presented as item D in the Notice of Deviation, enclosure:
1.
CE personnel were not in full agreement with the conclusion of site personnel that the HPSI valves had failed the pre-operational tests.
2.
CE stated that design verification methods were accomplished, relative to the subject valves, by the vendor using verification methods acceptable to CE.
The CE management representatives were advised that their comments would be considered in our documenution and review of this finding.
_9 DETAILS SECTION II (Prepared C. J. Hale)
A.
Persons Contacted G. M. Bevilacqua, Senior Specialist Clerk, QA Technical Services
- C. J. Bogacz, Supervisor, Mechanical Section, Group Quality Control
- F. G. Harvey, Senior Engineer, Engineering QA (EQA)
- G. J. Huba, Manager, EQA
- J. C. Packard, Compliance Supervisor, Group Quality Systems
- Denotes those present at tne exit meeting.
B.
Action on Previous Insoection Findings (Closed) Unresolved Item (Report No. 78-01):
It appeared that personnel performing surveillance of NDE activities were not qualified and/or re-qualified in accordance with topical and procedural commitments. A review of inspection personnel records and audit activities disclosed that certain individuals were performing surveillance activities with expired eye and NDE cer-tifications and qualifications. (See Notice of Deviation, Item A.)
C.
@dits 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Audit system is established which has organizational independence, authority, and is documented in pro-cedures and/or instructions in accordance with commit-ments.
b.
Audit records include a written audit plan, team selection, audit schedule, and audit notification to the person or organization to be audited.
c.
Members of the audit team are independent of any direct
-. - e tr~ in a T t i < :.i responsibility for the activities-being audited.-
- - Oc t- ' d; 2Proviisions e5 dst-for the reporting of the effectiveness
- of the QuaHtydssurancrprogram to responsible management.
, e.
The audit includes the use of checklists or procedures, detailed audit reports, and timely identification, acknowledgment, documentation of nonconfomances, and subsequent corrective action and verification.
f.
Audit reports contain the audit scope, identification of auditors, persons or organizations contacted, sumary of the results of the audit, the details of any noncon-formances noted, the recomendations for correction, and distribution of the report to responsible management.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Documents establishing program commitments:
Combustion Engineering Q:ality Assurance Program (Topical Report CEtiPD-210-A, fevision 3) Sections:
17.2.5, Training; 17.2.6, Management Evaluation of the QA Program; 17.16, Corrective Action; 17.18, Audits; Figure 17-5, PSG (Power Systems Group) QA Interfaces; and Table 17-3, Commitment Table of Regulatory Guides and AtiSI Standards.
b.
Implementing procedures to assure that procedural controls have been provided to satisfy topical commitments and items (a) tnrough (f) of the objectives section above:
(1) Design Quality Assurance (DQA) Manual procedure QADP 9, Audits and; implementing procedure DQA #0001, DQA Requirements for Auditing of f4PS.
(2) Group Quality Assurance (GQA) Manual procedures: QAP 2.1, Group Quality Assurance Training Program, including Appendix A, Qualification of a0E (t{an-Destructive Examination) Personnel, and Appendix B, Qualifi-cation of Audit Personnel; QAP 18.1, Internal Audits; QAP 18.2, In-process Audits of Vendors; QAP 7.1, Vendor Evaluation; QAP 16.1, Corrective Action Report (CAR); QAP 17.1, Quality Records Retention; and QAP 7.2, Vendor Selection.
i; v.:::.cm a '.erlic w.. Documents examined..to veri fy implementation; of. above -
m =c r:n rnr:;. r mairnprogram;and pmcedural requirements, and tcr satisfy
- ~
- rrme~ :w.m:::-" rimplementationmf"(~a) through (f) of objectives section:; _-
~ ~ -
_11-(1) EQA (Engineering QA)
(a) The following ar it reports and documents related d
to each of the audits, e.g. notifications, plans, and checklists:
GS-NPPC-0478-02, Audit of General Services' Production Planning and Control.
C-LD-02 77-01, Audit of Connercial Department's Licensing group.
E-PAD-0278-01, Audit of. Engineering's Plant Apparatus group.
E-PA-NSP-0177-01, Audit of Engineering's NSSS Performance Analysis group E-lCE-lS-0377-01 and E-lCE-0378-01, Audits of Engineering's Instrumentation and Controls g roup.
E-PH-CS/PHD/PHP/PHR-0677-01, Audit of Engineering's Physic; and Computer Analysis group.
D-MCD-MCM/MCC-1177-02, Audit of Development's Materials and Chemical group.
(b) EQA audit schedules for 1977 and 1973 including revisions.
(c) The training and qualification files of five (5)
EQA auditors.
(d) The scope and audit responsibility of EQA within CE's Power Systems Group was determined by a review of the EQA's
- rvey of audit candidates, Form 4-001.
Six (6) of thess surveys were reviewed and EQA determined t. tat it was not necessary to audit four (4) of these candidates (groups) based on these groups activities.
(2) Management Audits
,(a) Audits and related documents:
PSG-77-03M, Audit of Chattanooga Nuclear Operations.
(No audit number), Audit of Nuclear Products
. :... a s.. u.. s... a. c. ;
- . Manufacturing conducted December 14-15, 1977,
.: aa:a 2e:1 tr-2.
.9F report dated December 20, 1977.
- - - ~...-..-
. PSG-77-04M, Audit of Construction Services.
PSG-78-OlM, Audit of Purchasing and Production Planning.
PSG-78-02M, Audit of Engineering.
(b) Management Audit schedule for 1975 to 1981 from the Vice President, General Services.
(c)
Interoffice Correspondence (IOC) dated May 6, 1977, (Hoffman to Etheridge) providing a synopsis of the Management Audit Program.
(d) Review of the files of a manpower pool from which auditors are drawn to perform the management audits. Of the approximately 55 files reviewed, about 40 of the auditors were indicated as qualified based on an assessment by Group QA (GQA) personnel.
(3)
Internal Audits by Group Quality Systems (GQS) of GQA (a) Audits and related documents:
GQS-78-001, Total scope of this audit was to verify corrective actions relating to findings from a previous audit, GQS-77-013.
GQS-77-004, Audit of Engineering's Plant Apparatus group.
GQS-77-005, Audit of GQA's records and document control in Group Quality Centrol (GQC).
GQS-77-C08, Audit of EQA.
GQS-77-013, Audit of GQA, Purchasing, and Manufacturing Services (Production Planning).
GQS-77-017, Audit of EQA.
(b) Review of the training and qualifications files of three (3) GQS auditors.
(c)
Internal audit schedules for 1977 and 1978, including revisions.
~
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.a :
s av 4.
External Audits by GQC
- r."
'(a)" Review' of the training and qualifications n'-
files of four (4) GQC auditors.
. (b) The balance of the external audit, surveillance, and inspection program will be inspected under a different inspection module during a future inspection of CE.
3.
Findings The following deviations from commitment and unreso'lved items were identified in this area of the inspection.
Deviation (Notice of Deviation enclosure, Item B.).
a.
The IOC dated May 6,1977, from Hoffman to Etheridge, provides the only documented guidance for the conduct of Management Audits apart from the comnitments in the CE Topical CENPD-210-A. The following inconsistencies were noted during the review of management audit docu-mentation when compa. red to the documented guidance.
(1)
.here was no evidence that post-audit meetings were conducted with the management of the audited organi-zations in any of the management audit files reviewed.
These meetings are a requirement of ANSI N45.2.12 and of all other CE audit programs.
(2)
In some cases the individual :uditors signed their audit. reports, in others ths auditors signed neither the checklists nor the reports.
(3) One management audit file reviewed did not have an audit identification number, no audit plan, and there was no evidence that the Vice President, General Services, had approved the audit, au 'it team, or signed the audit report as implied by the IOC dated May 6, 1977.
(4) Neither the IDC dated May 6,1977, nor any other document reviewed by the inspector describes the qualifica-tion criteria for placing individuals on the man-power pool for performance of management audits, consequently at least one audit was performed using a team leader and one team member before these
_ individuals were identified as qualified.
...c.
.:..b.
Deviation (Notice'of Deviation enclosure, Item C~.)
,The CE internal-audit: program is the responsibility of
.t
- a,
n Group Quality. Systems.(GQS) of Group Quality Assurance
. (GQA).
In tha past year the scope and number of internal audits, as well as the number of GQS audit personnel, has decreased, for example:
(1)
In 1977 there were at least twenty (20) internal audits performed by GQS including six (6) of Engineering and Development activities, two of EQA, four (4) of General Services activities, and several follow-up audits to verify corrective actions.
Thus far in 1978, only one follow-up audit has been conducted and only one audit of General Services, GQA, Engineering, and EQA is scheduled for the remainder of 1978; and (2) The staffing of GQS has been reduced to one auditor, the Compliance Supervisor of GQS.
This individual's internal audit responsibility is further reduced by additional responsibilities that include scheduling, coordinating, and carrying out the management audit program, coordinating CE's CASE activities, support to the internal audit activities related to fossil plant manufacturing, and preparation for, coordination and folicw-up of NRC audits of CE.
In general, the comprehensive internal audit program described in CENPD-210-A and QAP 18.1 does not appear to be being implemented currently at CE.
c.
Unresolved Item No internal audits are being conducted by either EQA or GQS personnel relative to the activities of Licensing and Project Management personnel in the Commercial Depart-ment.
It appears that certain of the activities of these personnel would be subject to the requirements of CEMPD-210-A and 10 CFR 50, Appendix B, e.g. document control and design interfaces. This item will be considered unresolved subject to our inspection of these activities during a subsequent inspection.
d.
Unresolved Item
. = r EE ".-r ;,. Paragraph 17.10 of CENPD-210-A states that personnel
.. performing surveillance activities are qualified to ANSI -
_: r x
..v
=.
..u
.. '- N45.2.6L however, Table 17-3 states that this' standard is-not applicable. to the group (5072 Group QA) to which u
. these surveillance personnel are assigned.
- Further, Procedure QAP 2.1 which implements the requirements of ANSI N45.2.6, does not properly reflect all the require-ments of this standard.
Since the topical is not clear concerning whether ANSI N45.2.6 applies to surveillance personnel or not, and QAP 2.1 is somewhat inconsistent also, we are sending this item to our HQs group for further review. This item will be considered unresolved until the HQs review is completed.
4 e
9
-e
DETAILS SECTION III (Prepared by J. M. Johnsoi.)
A.
Persons Contacted
- G. P. Allocca, Supervisor, GQC-Reliability
- C J. Bogacz, Supervisor, GQC-Mechanical
- E. F. Boudreau, Supervisor, GQC-ICE W. Bowers, Lead Engineer, Valves M. Dalka, Senior Nuclear Systems Specialist R. W. DeVane, Project Manager, SONGS E. C. Gobell, Supervisor, Process Instrumentation i
A. Goldberg, Supervisor, Radiation Monitoring Group, ICE Design
- F. G. Harvey, Engineer, EQA
- G. J. Huba, Engineering QA Manager A. Jameson, Project Manager - St. Lucie F. W. King, Senior QA Engineer R. Kunze, QA Engineer, GQC i
- D. Mayer, Supervisor Planning and Procedures, Plant Engineering i
P. M. Maehan, Cognizant Engineer, SONGS, Process Instrumentation D. Provencher, QA Engineer-GQC J. C. Riek, ICE QA Representative J. L. Smith, Senior QA Engineer R. Terry, Cognizant Engineer, St. Lucie, Valves R. Thomas, Cognizant' Engineer, Safeguard Pumps D. R. Wade, Lead Engineer, Auxiliary Equipment II
- Denotes those present at the exit meeting.
B.
Evaluation of Supolier Performance 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented that provide for:
Establishing that the purchaser and supplier understand a.
the provisions and specifications of the procurement documents.
b.
Requiring the supplier to identify planning techniques'
~
and processes to. be utilized in fulfilling procurement requirements.
. c.
Reviewing documents which are generated or processed during activities fulfilling procurement requirements.
4 d.
Identifying and processing necessary change information.
e.
Establishing exchange method of document information
~
between purchaser and supplir*.
f.
Initiation of pre-and post-award activities, as necessary.
g.
Control of handling, and approval of supplier generated documents.
h.
Control of changes in items or services.
2.
t'ethod of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Topical Report CENPD-210-A, Revision 3, to identify CE generic comitments for evaluation of supplier per-formance. Note that CE QA Manual, applicable to Southern California Edison (SCE) San Onofre project, is identical.
b.
Chapter 17 of the Arkansas Power and Light FSAR for AN0-P.
(Arkansas Nuclear One - Unit 2) to identify project commitments.
c.
Chapter 17 of the Florida Power and Light PSAR for St. Lucie 2 to identify project comitments.
d.
Group Quality Assurance Manual Procedures: QAP 3.1 (Submittal Instructions for Technical CNinge Request -
TCR); QAP 5.3 (.NSSS Centract Requirements); QAP 6.2 (Submittal Instructions for Request for Approval or Review - RAR); QAP 7.1 (Vendor Evaluation), QAP 10.1 (Surveillance); QAP 15.1 (Submittal Instructions for Deviation of Contract Requirements - DCR); QAP 16.1 (Corrective Actic,n Report - CAR); QAP 18.2 (In-Process Audits of Vendors) to identify CE procedural require-ments, and controls over Objectives (a) through (h) above.
o, s... <-. e. "NPD-MPI-(Nuclear Power Department - Methods and Procedures m..,
Instructions): MPI;17.(Field Action Requests), MPI-18 r
r ::~
e'. m o-
'(QA.of Design)', and MPI-10 (Procurement Requisitions and cc
- i r-r
... a: Supplements) to identify procedural requirements committed
. to for ANO-2 project for P.O. changes and site-identified nonconfomances requiring modifications or design changes by a vendor, and to assure controls for Objectives (d) and (h) above.
f.
Quality Assurance of Design Manual procedure QADP 5.7 to identify procedural requirements for site identified non-confomances or deficiencies requiring design change or modification and to assure controls for Objectives (d) and (h) above.
g.
CE Procurement Manual Sections 20.7.1, 20. 7. 2, and 20. 7.3 to assure controls for Objectives (c), (d), (e), (h),
and (g) above.
h.
Documents examined associated with the prccurement of Process Instrumentation (P.O. 1470-9403324 and Supplement #6 to Foxboro for SCE-Southern California Edison):
Approved IMQP (Integrated Manufacturing and Quality Plan);
TCRs (Technical Change Requests) 1 through 12, including CE approval / disapproval; RARs (Requests for Approval or Review) 51-63, including CE appraval/ conditional approval; 21 audit reports for three Foxboro plants from March 25, 1975, to January 11, 1977, and associated CAR 77-005 and its closure. These documents were examined for confomance to the applicable procedural requirements listed above and for control over Objectives (a) through (h) above.
i.
Documents examined associated with the procurement of Excore Neutron Flux Monitoring System (P.O. 6370-9303853 for Arkansas and P.O. 1470-9400504 for SCE, both from General Atomics):
Corrective Action Report QC-CAR-76-020 and its closure; approved IMQP; six vendor audits performed from March 31, 1976, to December 7,1976, and associated CARS; CE letter dated March 31, 1976, from W. T. Tully.
These documents were examined for confomance to appli-cable procedural requirements and for control over Objectives (a) through (h) above.
j.
Documents examined associated with the procurement of a 4-Channel Camma Area Radiation Monitoring System for T ~ uia w '...GontdinmentiPurge Isolation Valves (P.O.1470-9602534
'.. p e -m from NMC:- Wuclean Measurement Company): approved IMQP;
~
DCRs (Deviatic'n of ~ Contract Requirements) 9602534-1
~
~'
. - ";i m
-(approved) aftd.;960253@2 -(status - void). -These documents
.i.+
mc m: me rwere examined-for conformance to applicable. procedural a..v v ~.u
.. requirements and forxontrol over Objectives' (a).through -
w:
(h)~abovei~~
g
. k.
Documents examined associated with the procurement of HPSI pumps (P.O. 940084 and P.O. Supplements 1, 5 & 6 from Bingham-Willamette for FPL):
CE (generic) Speci-fication #13172-PE-'.01; Wall Thickness Map and CE approval; B-W Liquid Penetrant Procedure H.10.3, Revision 8, and Addenda 8 and 13 and CE approval; Orawing E 15656, Revision A, (Seal Piping Drawing) and CE approval with comments, and Revision B incorporating comments and approved by CE; Letter LPCE 338 dated July 10, 1975; HPSI Pump Outline Drawing FD 14210014 and E15405X, Revisions 5 and 6; B-W Hydrotest Procedure E 30.33, Revision 2, and CE approval.
These documents were examined for conformance to procedural requirements and for control over Objectives (a) through (f) above.
I 1.
Documents associated with the procurement of 2" motor-i operated HPSI Header Valves:
P.O. 9403351 (October 29,1974) and Supplement 30 (May 23,1978, these valves were returned to vendor for modification because of flow problems) from Target Rock for FPL; P.O. 9101861, Suppl-ement 1 (March 21, 1972) from Target R.ck for ANO-2; P.O. 9403230 from Target Rock for SCE; P.O. 9100067 from Target Rock for LPL (Louisiana Powe and Light); CE Specification 6370-PE-705; RARs 1 through 14 (for weld and weld repair procedures, hydrotest procedure) for P.O.
9403351 and CE approvals; DCRs 1 through 6 for P.O.
9403351 and CE approvals Certification of Equipment and Records Checklist dated April 21, 1977, and Revision 1 dated July 13,1977, for 8 valves; Flow Test Procedure 1818, Revision A, and CE approval; Flow test results for valve #75C-002 and CE approval; FARs 6370-249, 6 '70-249A and 6370-2498 for ANO-2 and attached deficiency re ort re: stem damage (not flow problem); FAR 1370-013 (March 28, 1978) for SCE re: flow problem; FAR 9270-24 for LPL re: flow problem; CE letter by S.E. Gilley dated July 20,1973:
Flow Test Failure; Target Rock letter dated August 30, 1973, from Vito Liantonio and attached flow curve (C ) test results (approved); SCE letter AD12-y IR dated Juni. 16, 1978, to CE; SCE letter by H. B. Ray dated June 9,1978, to USNRC Region V identifying 50.55(e)
HPSI valves excessive pressure drop; CE letter by re:
F. C. Sernatinger dated September 19, 1977, to APL
. identifying revision to Section 6 of FSAR which lowers HPSI delivery curve; CE Letter dated July 7,1977, from E. H. Smith re: failure of HPSI flow-balancing test and identification of HPSI valves pressure drop (APL notiff-cation to NRC); CE letter August 3,1977, by P. H. Hepner re: ECCS-HPSI reanalysis, and valve modification. These documents were examined for conformance to procedural requirements and for control over Objectives (a) through (f) above.
3.
Findings In this area of the inspection, no unresolved items were identified. Two (2) deviations were identified. (See Notice of Deviation, Items D and E).
Related to both deviations, note that since no FAR was generated relative to the HPSI valve pressure / flow drop, CE formal documentation is lacking and informal documentation (internal memos) are hard to track to determine analysis and corrective action.
The P.O. Supplement is a QA record; the infonnal memos are not.
Concerning Notice of Deviation, Item D, CE did not review vendor (Target Rock) detail design of the valves.
CE did review and approve outline drawings for interface.
Flow testing of the initial valve was added in Supplement 1 to P0 9101861 for Arkansas, but standards were not specified.
The valve is similar to HPSI valves at Palisades (manufactured by Velan), by report, but Target Rock is a new vendor for the valves, and their new design changed tha plug (Subsequent redesign has gone back to a V-port plug).
CE did review and approve the Target Rock Flow Test Procedure and the results of the second flow test.
Note that a later internal memo from P. H. Hepner dated August 3,1977, states in part, " Safety Injection Systen tests on Arkansas, Unit 2, have indicated that the installed flow resistance of the HPSI Header Isola-tion Valves is significantly higher than the design values, resulting in reduced high pressure flows. Preoperations flow balancing tests indicated that flows required by the procedures for the HPSI pumps could not be obtained. Additional testing isolated the problem to the high pressure header isolation
-,,4..r
- cc. valvest ' A raiew.of. test data indicate that: the val.ve los'ses' c
m;"m..
are approximately-twi.ce the design values..Two options were available. One -was.the-use of revised flow data for. the ECCS
+: reanalysi's;. the.other was.. hardware modification e new valve plugs.,... Itwas estabmhed that the vendor's 0 tests were:'
m done.at flow rates much less.than design values.
,ihis appears '
a-to. ce one of the most probable causes for the deficiency."-
. Both ECCS reanalysis and valve modification were done for Arkansas.
ECCS reanalysis lowering values for Small Break Analysis eliminated the need on this plant for a 50.55(e) report.
Note that the FSAR for Arkansas states in Section 17, paragraph 17.1.3.3.3, "Desian by Others Outside of Nuclear Power Systems - Design Verification for equipment designed outside of Nuclear Power Systems is the responsibility of the engineering departments which prepared the purchase requisition."
Subsequent CE internal memo from T. L. Kettles dated August 3, 1977, identifies the problem in relation to other projects:
Valves for these projects were returned to Target Rock for modification and a retest at 100% flow is scheduled for the week of August 3,1978, and will be observed by CE.
C.
Verification Activities 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for verification activicies that provide for:
a.
The planning of verificatior, activities including identi-fication of the inspection sequence, hold and witness points, acceptance criteria, documentation required by the procurement document, and receiving inspection plans.
b.
Implementing source surveilli.nce including activities at supplier's facilities (i.e. inspections, audits).
c.
Measuring and test equipment including requirements for selection for accuracy and control sufficient to deter-mine conformance to specified requirements and cali-bration and control to recognized standards to determine validity of inspection and test results.
d.
Reporting results of source surveillance activities and evaluation of reports.
_________;.2.
Method of Accomolishment_ _
. 1.. __ :.t.:
a The p' receding cbjectiv'es.w~ re accomplished by.an examination e
of:
Topical. Repo~rt CENPD-210-A, Revision 3, to identify CE
-.i
- F;"
a.
.~a... _ m. f.. - -
generic ~ conmitments for evaluation of supplier' performance.
.... b.
Chapter 17 of the Arkansas Power and Light FSAR for AN0-2 to identify project commitments.
c.
Chapter 17 of the Florida Power and Light PSAR for St.
Lucie 2, to identify project conmitments.
d.
Group Quality Assurance Manual procedures: QAP 7.1 (Vendor Evaluation); QAP 10.1 (Surveillance); QAP 16.1 (Corrective Action Report - CAR); and QAP 18.2 (In-Process Audits of Vendors) to identify CE procedural requirements, and controls over Objectives (a) through (d) above.
e.
Documents examined associated with the procurement of Process Instrumentation (P.O. 1470-9403324 and Supplement
- 6 to Foxboro):
CE identification of witness and hold points (from IMQP); Surveillance reports dated February 22, 1978, December 20, 1977, September 20, 1977, June 20, 1977; Certifications of Equipment marked " Conditional" (approximately 20) and Records Checklists dated from November 10, 1977, to March 7,1978, for items from this purchase order including Flow transmitters, DP and Pressure transmitters, Level Transmitters and recorders, etc.
These documents were examined for conformance to the appli-cable procedural requirements listed above and for control over Objectives (a), (b), and (d) above.
f.
Documents examined associated with the procurement of Excore Neutron Flux Monitoring System (P.O. 6370-9303853 for Arkansas and P.O. 1470-9400504 for SCE) frcm General Atomics: CE identification of witness and hold points (from IMQP); Surveillance reports #1, #2, and #3; Cer-tification of Equipment dated November 12, 1976, and Records Checklist for items including Drawer Assembly, Preamps, Detector Assembly, Connectors and Cable.
These documents were examined for conformance to the applicable procedural requirements and for control over Objectives (a), (b) and (d) above.
g.
Documents examined associated with the procurement of Four Channel Gamma Area Radiation Monitoring System for Con-mm- - -1 y :P e-s tai.nment Purge; Isolation Valves (P.O. 1470-9602534 i frort NMCv(Nuclear Measurement Corporation)):- CE:identifi--
"mv nation of wi.tness; and-hold. points; Surveillance Report mm-
- t,
- 1; and-Audit of Crfterion XII implementation.
These
= documents were; examined.for conformance-to applicable ar w ; ' -
r c - ecc-
- ca ur procedural requirements and for control over.0bjectives (a) through (d) above.
-.~.
. h.
Documents associated with the procurement of LPSI pumps (P.O. 9500775 for FPL from Ingersoll-Rand):
Surveillance Report 16; Certification of Equipment and Records Check-list dated June 5,1978, for pump #1076150. These documents were examined for conformance to procedural requirements and for control over Cbjectives (a), (b) and (d) above.
i.
Documents associated with the procurement of 2" motor-operated HPSI Header Valves (P.O. 9403351 and Supplement 30 for FPL from Target Rock):
Surveillance Reports 8 through 12; Certification of Equipment and Records Checklist dated April 21, 1977, and Checklist, Revision 1, dated July 13, 1977.
These documents were examined for conformance to procedural requirements and for control over Objectives (a), (b) and (d) above.
3.
Findings 1
In this area of the inspection, no unresolved items were iden'ti fi ed.
One de'viation kas'i'de~ntified (See Notice of
+
)
Deviation, Item F).
6 Me W