ML19296C910

Discusses Adequacy of QA Program for Verifying Satisfactory Quality of S&W safety-related Matls & Svcs.Qa Program Is Not Successful in Preventing Subvendor Quality Problems.S&W Will Evaluate & Approve All Major Subvendors

ML19296C910
Person / Time
Site:	River Bend
Issue date:	12/11/1979
From:	Weigand J GULF STATES UTILITIES CO.
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
RBG-7003, NUDOCS 8002290051
Download: ML19296C910 (4)

Text

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GULF STATES UTILITIES COMPANY POST OFFtCE BOX 2951 .

BEAUMONT- TEXAS 77704 AREA CODE 713 836 6631 December 11, 1979 RBG 7003 File No. G9.5 7 '

Mr. Karl V. Seyfrit, Director __

J U. S. Nuclear 'legulatory Commission g l 6 a Plaza Drive b !Y N Suite 1000 Arlington, Texas 76011 Io g

Dear Mr. Seyfrit:

RIVER BEND STATION UNIT I Refer to: RIV Docket No. 50-458/79-05 This letter is intended to supplement my letter, RBG-6979, dated December 6,1979, and provide a brief review of the adequacy of the River Bend QA program for verifying the satisfactory quality of safety-related materials and services provided by Stone & Webster (S&W) and S&W's sub-tier suppliers.

Background

Gulf States Utilities (GSU) has delegated to S&W the procurement of materials and services which includes the verification of product quality. GSU recognizes its ultimate responsibility for product quality and provides for verification of product quality by monitoring S&W actions, participation in S&W audits of themselves and their suppliers, and by audit of S&W activities.

Personnel The S&W QA organization for the River Bend Project includes on and off site QA and QC personnel. At present, there are 72 QC people on site and a QA staff of 4 people which is supplemented with 4 QA people in the Cherry Hill Op eations Center. With increase in activity on site, the QA staff will grow to a peak of approximately 10, and QC will increase to approximately 170 at peak. Activities of the full-time project QA are supplemented by the resources of the S&W Corporate QA Department with NDT, Cost and Auditing, Field Quality Control, Quality Systems, and Procurement Quality Assurance divisions. The Procurement Quality Assurance (PQA) Division includes approximately 100 shop inspectors in district offices around the country.

800229o i03i

RBG 7003 Page 2 The GSU QA organization for the River Bend Project presently consists of 9 QA Engineers, including supervisors, with an anticipated addition of at least 2 more QA Engineers in 1980.

GSU considers the present and planned personnel resources of S&W and GSU adequate for the verification of product quality.

Program The S&W QA program provides for verification of product quality, including audits and inspections at prime vendor facilities and receipt inspection of delivered products.

Prime Vendors S&W's system mandates that all vendors have to be evaluated once a year. This evaluation consists of review of IR's, N&D's, oudits, Case Register, NRC rep;rts, and ASME audits, as applicable.

The S&W audit system includes, as a minimum, the requirement for an audit of all active Category I vendors once a year, or once in the life of the activity, whichever is shorter by PQA (shop fabricated items), Quality Cost and Auditing (site con-tractor), Engineering Assurance (Services and Engineering Services Scopes of Work), or a corbination of the above.

PQA audits all applicable criteria during each audit. Due to past project problems, special emphasis has been placed on Criteria III and VII. This emphasis includes: Purchase orders that contain adequate technical and quality requirements, how the subvendor was placed on the approved vendcrs list (AVL),

what actions are taken to maintain him on the AVL (audits, evalua-tions, and source inspection).

Past problem vendors are audited more frequently. (Graver and TASCO). This practice will ccatinue. Inspection plans are reviseu on vendors having had previous problems to increase the PQA activity.

GSU QA participates in about 15% of S&W's audits of their prime suppliers to evaluate the adequacy of S&W's audit program. GSU audits and participation in selected S&W audits has revealed problems and the present audit program is very effective in finding problems in a timely manner. Increased audits by GSU or participation in S&W audits would not be warranted at this time, and would do little to improve upon their effectiveness.

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RBG 7003 Page 3 Recei'/ing Inspection Receiving inspection is performed at the jobsite by Field Quality Control. The degree of receipt inspection is determined by various factors, including but not limited to: Amount of vendor QA inspection; amount of inspections, verifications, or sur-veillances required to be accomplished by PQA; and the ability of receiving inspection to verify quality. As a minimum, an in-spection is performed for completeness and physical damage, as well as verification that all quality related documentation is available. Where problem areas are identified, either through vendor audits or field problems, additional inspection beyond what is required by the specification or the quality program will be performed. Examples of this are reinforcing steel and Category I structural steel.

One action taken partly as a result of the audit conducted at Southwestern was to initiate plans for the on site ability to test cement / concrete, etc. Equipment is being purchased, persor.nel are being recruited to perform this task, and procedures are being developed; testing in parallel with outside services will commence when all three are available. It is anticipated that approximately three months of parallel testing will be required before independent testing will take over.

The receipt inspection program was last audited in July,1979, by S&W, and will be audited again in January,1980, by S&W.

The last audit of S&W's receipt inspection oy GSU was conducted in June,1979; it revealed an interface problem in S&W receipt of General Electric (GE) equipment, which has been resolved, and at present, no open audit items exist against the receipt inspec-tion effort. Receipt inspection is performing a sufficient job of controlling materials to assure the quality of safety-related items.

Subvendor Review The significant product quality problems encountered thus far on the River Bend Project have involved S&W subvendors. The present methods being utilized to monitor subvendors include:

1. S&W PQA District Chiefs review prime vendor's purchase orders to ascertain inspection requirements and that the prime has included appropriate technical and QA requirements.

2. In some cases, S&W has audited subvendors, due to product scope or complexity at the subvendor (W.J. Wooley, sub of Graver; CBIN, sub of CBI).

RBG 7003 Page 4

3. In certain instances, S&W QA has requested that the prime vendor submit to S&W his " surveillance plan" of subvendors.

Cases are Graver and TASCO, due to v. ope of work being per-formed by the sub.

4. GSU QA has performed random surveillances of subsuppliers when concerns with the prime vendor's QA program, or the implementation of the program warranted further investigation.

TASCO's supplier Florida Steel and Delta Testing's supplier Southwestern are examples. In both of the above examples the subsupplier in question had experienced QA problems.

The above methods, while conforming to the latest QA methodologies, have not been entirely successful in preventing quality problems at sub-vendors. Therefore, GSU is taking the following additional steps:

1. S&W has been directed to evaluate and approve all major sub-vendors on new contracts.

2. GSU has directed S&W to evaluate subvendors on existing contracts to insure that quality requirements are being met.

3. GSU QA will henceforth be more heavily involved in subsuppliers.

If you have any questions about this review please contact us.

Sincerely yours,

, , .=

. G. Weigan General Manager-Nuclear Projects JGW:bb