ML19305D490
| ML19305D490 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1980 |
| From: | Ellershaw L, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19305D487 | List: |
| References | |
| REF-QA-99900403 99900403-80-1, NUDOCS 8004150149 | |
| Download: ML19305D490 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900403/80-01 Program No. 51100 Company:
General Electric Company 175 Curtner Avenue San Jose, California Inspection Conducted: January 7-11, 1980 Inspecters:
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-0 C. f.J ale, Chief Date Prpgram Evaluation Section Vendor Inspection Branch h
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B. E. Ellershaw, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch Approved by: _
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-3 ~kd C. J @ e, Chief Date
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Program Evaluation Section Vendor Inspection Branch Summary Inspection conducted January 7-11, 1980 (99900403/80-01)
Areas Inspected:
This was a special inspection conducted to verify GE's responses to a deviation identified in Inspection Report No. 99900403/79-02.
The inspection involved sixty-four (64) onsite inspector-hours by two NRC inspectors.
Results: Errors or inaccuracies were found in information supplied by GE in their November 21, 1979 response to NRC. These related to assurances that feedwater spargers and thermal sleeves supplied by Marvin Engineering Co. were fabricated in accordance with all contract requirements and to the reported dates when the fabrication activities took place.
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2 DETAILS SECTION (Prepared by C. J. Hale and L. E. Ellershaw)
A.
Persons Contacted P. Aschoff, Procurement Quality Control Engineer N. E. Baltazar, Senior Quality Control Engineer W. C. Brady, Procurement Quality Control Engineer
- J. H. Breseke, Manager Procurement Quality Assurance, Nuclear Energy Control and Instrumentation Department (NEC&ID)
- C. L. Buckner, QA Systems Specialist, Quality Assurance.agineered Equipment and Installation (QAEE&I)
K. W. Hess, Manager, Mechanical Retrofits, Material and Technical i
Services i
D. Kuhlman, Manager Procurement and Inventory Control
- J. K. Powledge, Manager, QAEE&I R. B. Wright, QC Specialist, QAEE&I
- Denotes attendance at exit meeting.
B.
Action on Previous Inspection _ Finding - Inspection Report No. 99900403/79-02 The scope of this inspection was to verify GE's actions relative to the deviation identified in Inspection Report No. 99900403/79-02.
The essence of the 79-02 deviation was that GE had procured feedwater spargers from a non-essential supplier while the respective utility's L
contract with GE specified that these spargers should be procured as items essential to safety. GE's actions in response to this deviation were documented in letters to NRC Region IV dated August 21, 1979, October 3, 1979, and November 21, 1979. The purpose of this inspection was to verify the actions and information provided in these responses and included the following:
1.
Verify that the Marvin Engineering Company (MEC) QA Manual #7 provides QA coverage in the areas not covered by GE documents incorporated in the sparger purchase order, as stated in GE's November 21, 1979 letter.
2.
Verify the bases for GE's statement in their November 21, 1979, letter that the spargers purchased from MEC "were fabricated in accordance with the quality requirements of Purchase Order 205-AL709."
3.
Verify that GE's failure to pass through to their supplier the appropriate QA requirements was an isolated case, as stated in their August 21, 1979 letter.
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3 C.
QA Requirements of P.O. 205-AL709 1.
Objectives The objectives of this area of the inspection were to verify that the QA requirements imposed on MEC through PO 205-AL709 were equi-valent to those GE would impose on a supplier providing products in accordance with 10 CFR Part 50, Appendix B.
2.
Method of Accomplishment The preceding objectives were accomplished by review of the following:
QA documents imposed on MEC through PO 205-AL709 including:
a.
Quality Assurance Requirements-II (QAR-II), Revision 1.
QA Supplements #26, #28, and #29.
MEC QA Manual #7, Revision 0.
b.
QAR-I, Revision 2.
Sections (Items) of the MEC QA Manual #7 c.
Item 11, Vendor Survey Audit Surveillance, that provides for qualification, evaluation, and surveillance of MEC suppliers.
Item 25, Nondestructive Exauination Control, that provides for training, examination (written, practical, and physical),
and certification in accordance with SNT-TC-1A.
Item 28, Training, that provides programmatic training for all MEC personnel including their evaluation.
d.
Trip report of GE audit at MEC on May 25, 1979, concerning imple-mentation of the MEC QA Manual #7.
3.
Findings There were no deviations or unresolved items identified in a.
this area of the inspection.
b.
Northeast Nuclear Energy Company purchase order 604093, to GE, dated October 24, 1978, ordered the feedwater spargers as " Category I Safety Related" equipment.
It further states the equipment is to be furnished "in accordance with your quotation No. 416-2151-EH1, Revision 2, dated October 24, 1978 and revision letter G-EH-8-111 dated October 18, 1978."
Revision letter G-EH-8-111 acknowledges the safety related classification of the feedwater spargers for this order.
4 GE purchase order number 205-AL709 to MEC dated January 5, 1979, and subsequent revisions, do not specifically state Category I, Safety Related. For those suppliers from whom GE purchases safety related equipment, Quality Assurance Requirements - I (QAR-I) is imposed, normally.
Purchase order 205-AL709 does not address Category I, Safety Related equipment or QAR-I. The specified requirement is QAR-II, which is imposed normally upon suppliers of non-safety related equipment.
However, in addition to QAR-II, other QA supplements were imposed including the M2C QA Manual, along with 10 CFR 21 reporting requirements.
GE's position is that QAR-II requirements and the other referenced supplements, are equivalent to QAR-I.
c.
A comparison of the documents listed in 2.a., 2.b. and 2.c.
above show that they provide QA requirements equivalent to those of 10 CFR Part 50, Appendix B (QAR-I), when applied to the scope of the 205-AL709 purchase order.
Therefore, the equivalence statement in GE's November 21, 1979 letter appears to be correct.
d.
Implementation of MEC QA Manual #7 was verified by GE in selected areas during an audit at MEC on May 25, 1979.
D.
MEC Compliance With Purchase Order Requirements 1.
Objectives The objectives of this area of the inspection were to review and verify the bases of the statement by GE in their November 21, 1979, letter that the spargers fabricated by MEC were "in accordance with the quality requirements of Purchase Order 205-AL-709."
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Quality Control Standing Instructions (QCSI) No.
7.2.0, " Quality System Description For Engineered Equipment and Installation," dated July 9, 1979.
b.
Review of QCSI No. 7.2.18, " Quality Requirements on Material Requests and Purchase Orders," dated August 15, 1978.
c.
Review of Engineering Operating Procedure (EQP) No. 20-3.20,
" Engineering Equipment Procurement Operation Function," dated October 13, 1978.
5 d.
Review of the following GE purchase order to Marvin Engineering Company (MEC):
205-AL709.
Review of documentation packages provided to GE from HEC.
e.
L 3.
Findings GE's letters to NRC dated October 3, 1979, and November 21, 1979, a.
in response to NRC Report No. 79-02 provided the following information:
"An audit of Marvin Engineering Company on February 6, I
1979, and a review of their QA Manual # 7, Revision 0 and supplements, was completed on March 5, 1979, by QA Engineered Equipment personnel prior to work being started by Marvin Engineering Company on March 7, 1979. There were editorial i
corrections made to the QA manual prior to beginning of the machining of the Millstone Unit 1 items.
No corrective actions to the QA system were necessary after start of the I
order or to the hardware due to system deficiencies.", and
" General Electric has verified that the items purchased from Marvin Engineering Company were fabricated in accordance with i
the quality requirements of Purchase Order 205-AL709. The verification is supported by our source inspector reports and records including three trip reports of visits by the General Electric inspector at the Marvin Engineering Company during i
the period March 8, 1979 to April 27, 1979.
Additionally, an Equipment Surveillance Parameter Checklist was completed for i
the QC surveillance or verification activities that were accomplished during the period February 24, 1979 to April 27, 1979."
i b.
While an audit was performed by GE at MEC on February 6-7, 1979, and review of the MEC QA Manual and supplements was completed t
on March 5, 1979, work on the subject spargers had been started by MEC as early as January 4, 1979.
Certain machining, welding and liquid penetrant operations had been performed prior to March 7, 1979.
c.
The GE audit of MEC (February 6-7, 1979) identified certain deficiencies in the implementation of the MEC QA program. The conclusion stated in part, "... it is concluded that Marvin i
i is fully capable of doing a good job in fabrication of feed-water spargers. This is based upon getting the new QA Manual and any QA manual supplement submitteu, approved and fully i
implemented. A systems audit will be scheduled fu two-three weeks to audit to the new QA manual and to verify implementation, including all other commitments.
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A follow-up checklist to cover each open item identified during the February 6-7, 1979 audft was not provided to the GE Quality Control Representative (QCR) at MEC before April 18, 1979, which appears to be after all fabrication had been completed. Thus, verification of implementation of the MEC QA program at such a time would not appear practicable.
d.
The referenced trip reports (3.a. above) by the GE inspector is somewhat misleading, in that it would appear the inspector was verifying fabrication activities being performed at MEC between March 8, 1979 and April 27, 1979.
The first trip report was dated March 8, 1979 for activities performed on March 8, 1979.
i The second trip report was dated April 14, 1979 for activities performed between April 6,1979 and April 14, 1979. The third trip report was dated April 27, 1979 for activities performed on April 27, 1979 and this related to the final inspection and release of four thermal sleeve assemblies, which was an additional, separate entity, added to the purchase order in revision 1, dated February 16, 1979. The only inspect!on activity dealing with verification of fabrication, was delineated in the second trip report, dated April 14, 1979. This dealt with final liquid penetrant examination and final dimensional inspection after pickling, and a check of material traceability as documented by MEC.
i The Equipment Surveillance Parameter Checklist (ESP) mentioned e.
in the November 21, 1979 response (3.a. above), appears to contain anomalies.
(1) Item 1, states in part, " Visually inspect each weld for couformance.
There were ten criteria to be checked by 100% visual inspection; e.g., buildup, underfill, size and contour, etc. The GE inspector initialed and dated, as having 100%
visually inspected each weld for the ten criteria on March 22, 1979 (excluding the backside of one end plate to header weld). However, there were at least 4 welding operations per each of the 4 feedwater spargers that were performed after March 22, 1979.
(2) Item 2, states, " Correct filler material used, verify I
(minimum of one time) during fabrication, record each check."
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The verification was to be performed by a review of records.
The inspector initialed and dated, as having reviewed the records on two occasions; i.e., January 3,1979, and February 23, 1979. Regarding the January 3, 1979 date, the records show the first welding to have been performed on January 8, 1979.
(3)
Item 4 states, " Visual inspect all surfaces," with 4 cri-teria listed.
The GE inspector dated and initialed as having 100% visu-I ally inspected the equipment, on April 27, 1979.
In con-junction with Item 4, Item 7 states, " Verify all identifi-cation per GE drawings," with 3 criteria listed. The GE inspector dated and initialed, as having 100% visually inspected all markings for method, location and correctness, i
on May 22, 1979. The second trip report (dated 4/27/79) shows that the feedwater spargers were released for shipment by the issuance of a Product Quality Certification (PQC) i on April 14, 1979.
f.
The above findings indicate that GE could not have verified by i
objective evidence that the spargers were fabricated in accor-f dance with the QA requirements of PO 205-AL709.
This conclusion is supported by the fact that fabrication on the spargers was underway as early as January 4, 1979, according to MEC and GE records, which is contrary to the statement in GE's October 3, t
1979, letter which establishes March 7, 1979, as the start of i
fabrication.
Since most of GE's actions relative to MEC occurred l
after the February 6-7, 1979 audit, the unqualified statement by GE that the spargers were fabricated in accordance with the quality requirements in the purchase order is not supported l
by objective evidence.
i E.
Review of Other Purchase Orders 1.
Objectives The objectives of this area of the inspection were to verify that GE had implemented requirements for assuring that safety related items were procured only from suppliers that have been qualified as essential equipment suppliers in accordance with the QA Manual com-t mitments and applicable NRC requirements.
8 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following quality assurance procedures:
(1) QAP 4.1 revision 5, " Procurement Initiation Control" j
(2) QAP 7.5 revision 10, " Supplier Audit and Evaluation" (3) QAP 7.6 revision 7, " Issuing and Controlling Qualified Suppliers Manual" (4) QAP 7.11 revision 2, " Supplier Software Quality Verification" (5) QCSI 7.2.0, " Quality System Description for Engineered Equipment and Installation."
(6) QCSI 7.2.18, " Quality Requirements on Material Requests and Purchase Orders."
(7) QCSI 7.2.38, " Quality Assurance for Spare and Renewal Parts."
b.
Review of the following Manufacturing Procedures (MPs):
(1) MP 5.05 dated April 30, 1979, " Qualification of Nuclear Safety-Related Suppliers" (2) MP 5.10 dated September 6, 1979, " Controlling Production Procurement Documents" (3) MP 5.12 dated September 6, 1979, " Source Inspection and Release" (4) MP 5.19 dated April 27, 1979, " Supplier Document Review l
and Approval."
I c.
Review of the Quality Assurance Requirements Application Matrix dated July 16, 1979.
i d.
Review of fifty-seven purchase orders, which included both nuclear safety related and nonsafety related suppliers.
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Review of Qualified Suppliers Manual to assure the designated e.
suppliers of safety related equipment in d. above, have been qualified as safety-related suppliers.
f.
Review of the audits and evaluations performed by GE on those designated safety-related suppliers, g.
Verification that quality assurance requirements had been incorporated in the procurement documents.
3.
Findings a.
No deviation from commitment or unresolved items were identified in this area of the inspection.
b.
Based on the limited sampling of GE's procurement activities during this inspection, it appears that the condition that resulted in the deviation in report 99900403/79-02 was an isolated case as stated in GE's August 21, 1979 letter. Fur-ther, the Manager, QAEE&I, issued a memo dated August 1, 1979, advising his QC Engineers of this deviation and their procedural requirements which should have prevented the deviation. This memo provided the preventive action described in GE's August 12, 1979 letter.
Inspection of GE's control of procurement activities l
will be continued during our next inspection.
F.
Exit Meeting A meeting with GE representatives was held at the conclusion of the inspection on January 11, 1979.
In addition to those denoted in para-graph A above, those in attendance were J. Barnard, Manager, Product and Quality Assurance Operation (P&QAO)
R. C. Boessen, Manager, Technical and Administrative Programs, Nuclear Power Systems Division A. Breed, Manager, QA Systems, P&QA0 D. H. Ferguson, Manager, Quality Assurance, NEC&ID J. A. Kahermanes, Senior Engineer, Quality Assurance and Operating Methods A. I. Kaznoff, Manager, Product assurance, P&QA0 i
D. E. Lee, Manager, Quality Control, Engineering Services J. L. Murray, Manager, Quality Assurance, Engineering Design R. E. Pingleton, Senior QC Engineer, NEC&ID i
B. A. Podberesky, Manager, Engineered Equiptent Procurement i
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10 L. V. Stonebraker, QA Specialist, Nuclear Services Department L. D. Test, Principal Engineer, NEC&ID R. J. Valencia, Audit Coordinator, Engineering Services The scope and findings of the inspection were reviewed with the GE representatives. Concerning the two errors identified in GE's letters to the NRC, the Manager of P&QA0 advised the NRC inspectors that GE would correct these items in future correspondence.
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