ML20006D548

Discusses Insp of Ebasco Procurement Activities at Facility. Involved Ebasco Personnel Will Be Trained on Requirements Prior to Initiation of Any New safety-related Purchase Orders as Required by Quality Program Manual

ML20006D548
Person / Time
Site:	Waterford
Issue date:	10/20/1989
From:	Healy C EBASCO SERVICES, INC.
To:	Brach E Office of Nuclear Reactor Regulation
References
NUDOCS 9002140034
Download: ML20006D548 (3)

Text

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' ESASCO SERVICES INCORPORATED J i T 210 clay A'venue, Lyndhurst, NJ 070713507, (201) 896-5000  ;

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3 October 20. 1989 .;

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L .Mr. E. William-Brach, Chief- 4

,; ' Vendor _ Inspection Branch

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Division of Reactor. Inspection &. Safeguards - l

' Office.of Nuclear Regulatory Commission: l

% 'U.S.l Nuclear. Regulatory Commission 1 w ,

. Washington,.D. C.' 20555- 1 t

SUBJECT:

INSP CTION 0F'EBASCO PROCUREMENT ACTIVITIES AT THE WATERFORD 3 SITE J

REFERENCES:

NRC letter dated, March 31, 1989, Docket No. 99900505/89-01_-

N NRC letter dated, July 18, 1989 Docket No. 99900505/89 ~Ebasco letter, same subject' dated April 12, 1989-Ebasco letter, same. subject, dated ~May 22,-1989- 1, Ebasco_ letter, same subject, dated June 19,' 1989 l Ebasco'. letter, same subject, dated August 11, 1989 '

Dear M6 Brcch:

LThe . purpose of:this. letter is to summarize Ebasco.'s progress to date, identify -  !

current conclusions, and establish a schedule for completing our evaluation.

and response to theLNRC cor.cerns documented in reference (1). Whereas Ebasco'ss .

' initial: approach to! addressing the-NRC concerns was focusedion 10cating old 1

^ departmental;and personnel working files.to use.in conjunction 'with the Project's Quality Records and provide a basis for resolution, this has not proven to be

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9 productive.' Accordingly, Ebasco re-oriented'its' approach to _ conducting an u, ,

Engineering;re-evaluation of_ the items in question, their appropriate design 1

. basis classification,Tand hence an assessment of the safety-significance to the l Waterford SES Unit 3 Nuclear Power Plant of the questioned material pracurements. p lWith-respect;to the Notice of Violation which stated: f j

Section 21.31 of 10 CFR 21 states, in part, that each individual l corporation, partnership or other entity, subject to the j

.. regulations of this part,- shall assure that each procurement 1

. document for a. facility, or a basic component issued on or-after .i

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f LJanuary 6, 1978 specifies, when applicable, that the provisions a y '

of 10 CFR 21 apply.

i Contrary to the above, Ebasco Services Incorporated placed two l M purchase orders, WP3-13587 and WP3-13768D, for safety-related i electrical material for the Waterford 3 SES without imposing  !

the requirements of 10 CRF 21 on the supplier. (89-01-01) 3L j$g2 gggj4 g h 2 l m y  ;

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RESPONSEi Ebasco acknowledges that field purchase orders WP3-13587 and WP3-13768D were placed as safety-related purchase o'rders,without imposing the requirements of 10 CFR 21 on the supplier. The error made by Ebasco was in e rking the y . purchase orders safety-related. ,

Ebasco's review of. field purchase orders at the Waterford SES Unit 3 site identified several additional examples of this inconsistency for procurements associated with Ebasco Specification LOU 1564.249A, " Conduit Boxes and Fittings, Interface Material - Non-Seismic".

. Ebasco feels that despite the design classification of these items as non-safety related,- an administrative decision was made by Ebasco field personnel to identify the purchase orders as safety-related; probably to obtain an increase in Quality-Control receiving inspection and manufacturing records review.-

T The design basis classification for these items procured for Waterford SES Unit 3 was non-safety related and Ebasco concludes that,10 CFR 21 was not applicable. It is noted that there were no other Ebasco Specification (s) for

-Waterford SES Unit 3 for these items at a different design classification and hence, no design application for these items requiring a higher grade.

. The applicability of 10 CFR 21 to safety-related items or material. is mandated 4' in Ebasco Quality Program Procedure, N-23, Reporting a Defect / Noncompliance to <

the NRC. However, to provide increased visibility to this requirement, Ebasco's 1 Nuclear Quality Assurance Program Manual, ETR-1001, Section(s) QA-II-5 and QA-- j III-3 will be revised as follows:  ;

2.1 Procurement' documents shall make provisions for the following:

Newsubparagraph2.1(f)Notificationtothesupplierof 4 safety-related items, material or services of the applicability j of 10 CFR 21. j A revision to ETR-1001, including this change is currently under internal review l and is scheduled to be submitted to the NRC within the next few weeks.  ;

. Involved Ebasco personnel will be trained on these requirements prior to  !

initiation of any new safety-related purchase orders as required by Ebasco  ;

Quality Program Manual (ETR-1001) section QA-I-3, Personnel Indoctrination and Training Program in Quality Assurance. .

With respect to the Notice of Non-conformance which stated:

i Criterion V of Appendix B to 10 CFR Part 50 states: " Activities j

^affecting quality shall be prescribed by. documented instructions, g

. procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative acceptance criteria for j determining that important activities have been satisfactorily 1 accomplished. '!

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A Ebasco Services Incorporated Procedure No. ASP-1-5, Issue "E", dated April ~20,- 1978', " Quality Assurance Evaluation of Suppliers," states in Section 6.1 that safety-related items and services shall be '

purchased _only from suppliers included on Ebasco's Approved Supplier

-List.

Contrary to the above, the NRC inspectors identified 35 Ebasco initiated purchase orders for various safety-related electrical material placed with the GISMO Company without the suppliers being s listed on Ebasco's Waterford 3 or New York headquarters Approved Suppliers List. (89-01-02) ,

PRELIMINARY RESPONSE:

Ebasco acknowledges that purchase-orders, marked safety-related, were placed '

by Ebasco with Guarantee Instrument Systems of Missouri (GISMO) without GISMO appearing on the Ebasco Approved Suppliers List (ASL). This is a violation of Ebasco's Quality Assurance Program Manual (ETR-1001), section QA-I-5.

Quality Assurance Evaluation of Suppliers / Contractors. .

During our review, Ebasco has identified two (2) additional purchase orders placed with GISMO during the period of interest and on (1) purchase order placed prior to the period of interest for which the concern is also applicable. ,

Ebasco notes that the subject purchase orders placed with GISMO were for the fabrication of Ebasco designed electrical junction or pull boxes in accordance with Ebasco Specification'LOV 1564. 249R, Fabricated Boxes, Covers, and Associated Hardware for Electrical Systems - Interface Material - Seismic Category I and Ebasco's Box detail drawing LOU 1564 B - 353.

.Due to the scope and nature of this concern, Ebasco has re-oriented its' approach to conduct an engineering re-evaluation of all of the box designs included in the LOU.1564-B-353 drawing. In this manner we are assured of including all possible box designs in the evaluation. ' Tentatively, we consider that these seismically i analyzed-interface items, could have been classified as non-safety-related. Hence the conclusion of no-safety significance could be reached.

The engineering evaluation is currently scheduled to be completed by December 1,'1989 and Ebasco will submit a final response by December 18, 1989.

Ebasco will continue to -keep your office informed as our evaluation progresses- i and should it be determined that there is a safety significance to these concerns, Ebasco will'immediately process the condition, as required by out implementing procedures. Should you have any questions, please advise.

Very truly ours, s

C. R. e ly Director Quality Assura ce CRH:WS:mmb cc: B. R. Mazo