ML20010G219
| ML20010G219 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/09/1981 |
| From: | Oprea G, Oprea J HOUSTON LIGHTING & POWER CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, ST-HL-AE-711, NUDOCS 8109150449 | |
| Download: ML20010G219 (17) | |
Text
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- 1 E2's Ille Cog The Light comPuy i i"""" i;x a "x & is- < > o >i"' "" i'"" ~' <x"' ' '""' (3 > 28-"2 "
September 9, 1981 ST-HL-AE-711 SFN: V- 0'. 30
- g Mr. Karl Seyfrit g*k b Director, Region IV - 'C-Nuclear Regulatory Commissica 611 Ryan P1aza Drive, Suite 1000 % SED J.11981 791
~j Arlington, Texas 76012 jA DYN" 2/
Dear Mr. Seyfrit:
South Texas Project Units 1&2 Occket Nos. STN 50-498, STN 50-499 Fifth Interim Report Concerning the Breakdown in the Quality Program - Procurement Cycle of Purchased Materials On June 13, 1980, Houston Lighting & Power Company notified your of fice, pursuant to 10CFR50.55(e), of an item concerning a br?akdown in the quality program for the procurement cycle of purchased materials and equipment. Please find attached a revised program description and associated revised implementation schedules for resolving this item. Incorporated into the program description is a status of the review concerning this item. Change bars are provided in the margin to highlight material changed from the Fourth Interim Report. In our Fourth Interim Report, we identified that the next report would be submitted by September 24, 1981; however, due to the latest revisions to the Vendor Control Program, wa are submitting the report early. The next reoort concerning this iten will be submitted by October 23, 1981.
l j If there are any questions concerning this item, please contact Mr. Michael E. Powell at (713) 676-8592.
Very trulrypurs, ll1Q L +
[ i. M'. . rea,t'y.
( Execu ive Vite President MEP/anj Attachments {
h.
8109150449 810909 7 PDR ADOCK 05000498 l S PDR
Ilouston 1.ighting & Power Company cc: J. H. Goldberg September 9, 1981 J. G. Deweasu ST-HL-AE-711 D. G. Barker SFN: V-0530 C. G. Robertson Page 2 Howard Pyle R. L. Waldrop H. R. Dean D. R. Beeth J. D. Parsons J. W. Williams J. W. Briskin J. E. Geiger STP RMS H. S. Phillips (NRC)
J. O. Read (Read-Poland,Inc.)
M. D. Schwarz (Baker & Botts)
R. Gordon Gooch (Baker & Botts)
J. R. Newman (Lowenstein, Newman, Reis, & Axelrad)
Director, Office of Inspection & Enforcement Nuclear Regulatory Commission Washington, D. C. 20555 R. L. Range /G. W. Muench Charles Bechhoefer, Esquire Central Power & Light Company Chairaan, Atomic Safety & Licensing Bnard P. O. Fox 2121 U. S. Nuclear Regulatory Commission Corpus Christi, Teras 78402 Washington, D. C. 20SSS R. L. Hancock/G..Pekorny Dr. James C. Lanb, III City of Austin 313 Woodhaven Road P. O. Box 1038 Chapel Hill, North Carolina 27514 Austin, Texas 78767 J. B. Poston/A. venRosenberg Mr. Ernest E. Hill City Public Service Board Lawrence Livernore Laboratory l P. O. Box 1771 University of California l San Antonio, Texas 78296 P. O. Box 808, L-46 Livermore, California 94550 Brian E. Berwick, Esquire Lilliam S. Jordan, III Assistant Attorney for the State of Texas Harmon & Weiss l P. O. Box 12548 1725 I Street, N. W.
l Capitol Station Suite 506 Austin, Texas 78711 Washington, D. C. 20006 i
Lanny Sinkin Citizens for Equitable Utilities, Inc.
l Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn 1
5106 Casa Oro Route 1, Box 1684 l San Antonio, Texas 78233 Brazoria, Texas 77422 Jay Gutierrez, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20SS5 Revision Date 7-28-81
Page 1 Fifth Interim Report Concerning Breakdown in Quality Program -
Procurement Cycle of Purchased Material September 9, 1981 1.0 PURPOSE 1.1 General
~
The purpose of this report is'to describe the current South Texas Project Activities associated with the investigative review and verification of the procurement cycle activities for Houston purchased safety-related equipment and material.
The completion of these activities will result in releare of these purchase orders for continuation of construction activities.
This report describes the differences between current review activities and those reported in earlier reports to the USNRC, as well as the rationale supporting these necessary changes.
This report also includes the most current schedule for completion of the milestone activities associated with this
! effort and a definition of status as of July 31, 1981.
1.2 Background
During a review of the Vendor Control Program of representative purchase orders, several generic areas of concern in the procurement cycle were identified. These were i reported to the US Nuclear Regulatory Commission as follows:
- 1. Review of vendors' Quality Assurance Program prior to award of contracts was not, in some cases, properly documented in accordance with project procedures.
1
- 2. Approved design change documents were being utilized by vendors prior to or without issuance of a Purchase Order Change Notice making them contractually binding.
- 3. Interface agreements used to define the communication link between-the South Texas Project and vendor and to identify ,
the processing requirements of vendor-related documents were not, in some cases, imposed or strictly followed.
- 4. Approved Supplier Deviation Requests were apparently utilized to make generic changes to design specifications without the issuance of required Document Change Notices to those specifications.
Page 2 S. Vendor documentation requirements for retention at their facility and submittal to the project for review and approval were not, in some cases, adequately defined and/or implemented.
- 6. Trending of vendor audit deficiencies and nonconforn..nces to identify repetitive deficiencies, evaluate root causes, and implement corrective action to prevent recurrences, was not bei..g effectively accomplished.
- 7. Planned vendor surveillance inspection activities were not being performed, nor did documented etidence exist to substantiate the acceptability of deviating from these planned activities.
- 8. Verification of personnel certification for individuals performing vendor surveillance activities was not, in some cases, adequately documented.
- 9. Materials received at Site reflected shipment fron vendors' facilities other than those locations which had been approved by the project.
Due to the apparent failure to develop and/or implement a totally ef fective quality program during the procurement cycle, the quality status of purchased safety-related matesfals and equipment must be reestablished. A contrciled-release procedure was initiated at the STP site on June M,1980, to provide quality control verification or requirea records for safety-related naterials and equipme,1t, prior to written release by Quality Engineering to Constructico.
In October 1939, the Vendor Control Program (VCP) Task Force Was established to: reverify, through development of Baseline
- Procurement Packages, that the projer.t coordtmants were being properly imposed; perform the investigative review; resolve identified discrepancies to the extent possible; develop and assign recommended disposition actions on the remaining items; and monitor their impler.antation and closecut.
2.0 DEFINITIONS For purposes of uniform understanding and use throughout this report, the following terms, activities, and responsibilities are defined:
0 l Quality Commitments - Any regulatory guide, code, or standard i related to the technical or quality design of the equipment or l material.
0 l Baseline Requirements - Requirements that are or should be in l force to assure that quality commitments are met.
l
Page 3 0 Vendor Control Pro vam (VCP) Task Force - The group assigned tha responsibility for establishing the baseline requirements, reviewing the procurement cycle ror conformance thereto, and monitoring the implementation of final dispositions. The VCP Task Force consists of the Reviewing Engineer-Quality (RE/Q) group, the Reviewing Engineer-Technical (RE/T) group, and Investigative Review Group (IRG), a7d other personnel required for administrative, clerical, and management support.
The organization chart for the VCP Task Force is Attachment "A".
O Provisional Documents- Documents which contain or reflect the requirements still outstanding and needed to comply with quality commitments. Since these documents are developed by the VCF Task Force, they are tentative and are identified as provisional until reviewed and apprcved in accordance with Project procedures.
O Baseline Procurement Package - The documentation, existing or provisionM, which describes exactly what is to be procured under a given set of conditions the essential cuali'.y reouirements necessary to meet those conditions, and the activities necessary to complete a procurement cycle.
o Procurement Cycle - The process of obtaining proper equipnent and naterial for jobsite activities. This process starts with specification preparation, and continues through bids, purchasing, manufacturing, delivery, and receiving inspection at the jobsite.
3.0 PROGRAM 3.1 Technical Reference Document Technical Reference Document (TRD) A700GP007, " Vendor Control Program for Safety-Related Equipment and Materials", and supporting policy documents and work instructions have been generated and are being used to control all aspects of PL associcted with this activity: responsibilities, interraces and authorities, activities, work process logics, review requirencats, format of report and records, etc.
The relationships between the TRD and other documents are shown on Attachment "B".
3.2 Work Process Logic The work process logic for the overall Task Force activity is shown in flowchart form on Attachment "C".
Page 4 3.3 Generation of VCP Baseline Procurement Packanes Engineering and Quality Assurance (QA) Engineering concurrently perform detailed reviews of all procurement documents and referenced standards pertinent to each purchase order.
Engineering performs an in-depth review to trace technically-based quality commitments from the Final Safety Analysis Report (FSAR) through the existing purchase
- pecification.
QA Engineering performs an in-depth review to ensure that the quality assurance commitments from the South Texas Project QA Program are included, if applicable to the purchase order being reviewed. They also define the Vendor documentation requirements and identify any support or Vendor documentation necessary to meet or substantiate identified ouality commitments.
The reviews will yield the following:
o Determination of the technical and r;uality reovirements, necessary to support quality commitments, that were initially contained in the purchase order.
O Determination of the changes in requirements, necessary to support quality commitments, that have been made during the life of the purchase order, through the initial review date.
O Determination if quality commitments are supported by appropriate requirements in the present purchase order package.
o Identification of revisions necessary to support the stated quality connitments and preparation of provisional documents to reflect them.
( Engineering and QA Engineering will combine the results of their individual development activities to compile the Baseline Procurement Package. The Baseline Procurement Package shall be reviewed by responsible individuals within the Project Engineering organization, in order to ensure that the proposed changes to existing project documents, as indicated by provisional resolutions or revisions, are tentatively acceptable subject to final review and approval following the completion of the investigative review.
I l
Page 5 3.3,A Differences from Previous Methodoloay:
- 1. Correspondence Review:
Past Practice: Formerly, Engineering was reviewing all correspondence related to each purchase order, to identify any changes in requirements that have been initiated therein.
Current Practice: Correspondence is now utilized on1.y as a tracking device to facilitate location of objective evidence that required actions have been taken.
Rationale for Change: Until a change is documented by an official STP project record, i.e. P. O. Change Order, Supplier .
Deviation Request, Non-Conformance Report, etc., the proposed I change is only a " concept".
The R" views of the correspondence generated nany time-consuming, non-productive searches for records of activities that were never performed. For example: a Vender may have suggested in correspondence that a change be initiated; subsequent telephone conversations between the interested parties determined that it was not feasible to proceed with the suggestions; unless well-documented, by accurate reference to the original correspondence, the decision to not change could not be traced. (Such decisions to not change are unimportant, in most instances.)
- 2. Review of Baseline Procurement Packaac by Project Engineering Organization:
Past Practice: Following compilation of the Baseline Procurement Package by Engineering and QA Engineering, it was sent directly to the Investigative Review Group.
Current Practice: The Baseline Procurement Package is reviewed by responsible individuals within the Project Engineering organization.
Rationale for Change: The review by responsible individuals within the Project Engineering organization was undertaken in order to ensure that the proposed change to existing project documents, as indicated by provisional resolutions, are tentatively acceptable subject to final project review and approval following the completion of the investigative review.
I 3.4 Investigative Review Activity Brown & Root has engaged the services of NUS Corporation (HUS) for the purpose of performing an independent, third-party investigation and review of the Vendors' activities durinn the procurement cycle of safety-related materials and equipment.
t _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Page 6 NUS, using the 3r,eline Procurement Package as basic criteria, reviews the activities of each Vendor to ensure that the essential quality requirements have been satisfied.
NUS Corp. Quality Assurance Plan for NUS Project 348601 established the basis for the review activity. The Plan is implemented through instructions written and controlled by NUS.
The investigation and review consists of the following:
0 Review and evaluation of the Vendors' QA Programs, including their QA/QC manuals and the implementation thereof; O
Verification of proper Vendor documentation to support essential quality requirements defined in the Baseline Procurement Packages, and identification of discrepancies thereto; and 0 Verification of proper disposition of NUS-identified discrepancies and observations, including initiation of action by B&R on required provisional resolutions identified in the Baseline Procurement Packages.
When the review of each purchase order is conoleted, an NUS final report summarizing tne results of the review will be generated. Included in the report will be: all documents reviewed or records review listing of documents not returned; all discrepancies generated and their final status; and analysis of the percentage of documents reviewed relative to the total order; and any other information which related to the quality status of the purchase order.
3.4,A Differences from Previous Methodology
- 1. Concentration on Vendors' QA Programs, Records, and Activities:
Past Practice: From establi:hing the Baseline Requirements through the investigative review activities for the first four purchase orders completed, undue emphasis was placed upon B&R l procurement cycle activities. This improperly-placed emphasis l resulted in the re-identification of discrepancies similar to i those originally. reported to the USNRC (see 1.2), without re-establishing the quality status of the equipment being investigated.
1 l Current Practice: Full emphasis is now placed upon investigation and verification of the Vendors' QA/QC activities in order to ensure that pertinent quality elements of their furnished products are identified and described, performed, and documented.
Page 7 Rationale for Change: The deficiencies in past B&R activities related to control of the procurement of safety-related materials and equipment have been documented and reported to B&R Management, HL&P Management, and the USNRC.
These conditions have been thoroughly analyzed, and the causes for the conditions have been determined. On the STP project, measures have been established and documented to assure that through proper implementation that future occurences will be prevented.
- 2. Investigation and Evaluation of Vendor's QA Programs: !
Past Practice: NUS did not review and evaluate Vendors' programs; instead, they reviewed the documentation of B&R pre-award surveys, audits, in-process surveillance, etc. This resulted in the reidentification of discrepancies similar to Section 1.2, items 1, 6, 7, and 8.
Current Practice: Utilizing each Vendors' currently-applicable QA/QC Manual, and all past revisions available witnin B&R, NUS performs a detailed analysis and comparision against the applicable sections of ANSI N45.2 and applicable daughter standards,10CFR50 Appendix B, and other Baseline requirements.
An NUS investigative review team then visits each Vendor's facilities in which quality-related activities have been performed, in order to verify the satisfactory implementation of the QA Program as described in the QA/QC Manual. Also, the Vendor's historical file of QA/QC Manual revisions is reviewed, from the date of the original purchase order to the present.
Rationale for Change: This type of investigation ensures the Vendor's general overall compliance with the Baseline requirements. These investigations will also identify any apparent discrepancie in meeting these requirements, thereby following early and detailed study, evaluation, and remedy.
- 3. Sampling of QA Records on Certain large-Volume Purchase Orders (Note: This concept is not yet being utilized; methods are currently being investigated for incorporation.)
Past Practice: All available Vendors' documentation is being reviewed by NUS on the basis of 100% inspection for accountability, traceability, legibility, and completeness.
Future Practice: On certain large-volume purchase orders, e.g. shop-fabricated piping, hangers, structural steel, etc. ,
the sampling procedures and inspection by attributes described by MIL-STD-10SD will be utilized, where applicable, to verify
Page 8 compliance of the associated QA Records with the essential quality I .~ii rements.
On purchase orders where the provisions of MIL-STD-10SD cannot
- be shown to apply, inspection for accountability of all available Vendor documentation records will be periormed by NUS.
Rationale for Change: Site QA Engineering is responsible for review of documentation, purchase orders, design changes, etc.
(Show Cause Item AB). STP QAP-10.1 " Inspection Planning" (Rev.1, S/16/81) covers this activity.
The VCP Task Force activity is intended to provide satisfactory evidence that the Vendors have complied with the Baseline quality requirements during the period of time covered by the 10CFRSO.SS(e) reported incident.
To avoid substantial duplication of effort by STP Site Quality Engineering and NUS, NUS will review the Vendor's QA Records, using MIL-ST0-10SD sampling techniques where applicable, to assure accountability of the records. For any generic problems and discrepancies identified, dispositions will be developed and implemented. The total review of the records for technical adequacy and compliance will be performed by STP Site Quality Engineering.
3.b Resolution of Review Findings:
Any discrepancies identified by NUS, for which corrective actions cannot be completed by the VCP Task Force personnel, and any finding of noncompliance to quality commitments identified during the generation of the VCP Baseline Procurement Packages will be documented on a Disposition Implementation Report (DIR).
The manager of the VCP Task Force will assign the DIR to the
- appropriate authority on the STP project for inplementation in accordance with established STP project procedures and requirements.
3.b,A Differences from Previous Methodology:
- 1. Determination of Required Project Actions:
Past Practice: It was planned that any Baseline Requirements that were not contractually inposed by the procurement documents would be incorporated by the STP project into a Purchase Change Order, without consideration of the production and delivery status of the order.
Current Practice: Upon receipt of the DIR, STP nroject personnel will evaluate the recommended disposition actions
Page 9 for determination of the optimum methods for accomplishment.
Evaluation factors will be:
O Productions and delivery status of the purchase order o QA Program status of the Vendor 0 Vendor's past compliance with Baseline Requirements, although not contractually imposed in existing procurement documents 0 Importance of malfunction or failure of the items to plant safety 0 Complexity or uniqueness of the itens, versus the degree of standardization 0 Degree to wnich functional compliance can be demonstrated by inspection or test Depending upon the results of the project evaluations, the following actions may be taken: revise project documents and impose additional contractual requirements on the Vendors; expedite Vendors for existing requirements that are defined but have not yet been met; clarify or document Baseline requirements that have been met by the Vendors' activities but that are not contractually imposed; define and monitor additional inspections or tests on equipment delivered to the jobsite, in. order to verify functional comoliance.
Hationale for Change: The current practice will require implementing a revision only when such revision will cause a change in the actions of either the Vendor or Brown & Root.
The originally-planned actions did not consider the status of the order, thereby ignoring the commercial liability inherent in renegotiating the contract, most elements of which may have been successfully and satisfactorily completed.
If the evaluation indicates that B&R can perform inspections, tests, or other verification activities to satisfactorily prove the quality and acceptability of the product, these required B&R actions will be documented, inclemented, and monitored to completion by the appropriate STP project organizations.
3.6 Update Purchase Orders When the results of the STP project evaluation indicate that Baseline Requirements have not been properly imposed, and the imposition of these requirements cause a change in the actions of the Vendor, a Purchase Change Order will be implemented.
This task will ce accomplished utilizing standard project procedures, since at this point of the activity cll docunents
Page 10 utilized will be those that have been revised, reviewed, and approved in accordance with project requirements.
3.7 Correct Vendors' Deficiencies This task will be accomplished utilizing standard project procedures. However, there will be special emphasis given to the receipt, identification, and review for adequacy of these items in order to facilitate the final resolution and closeout of discrepancies, and to allow for subsequent release for continuation of construction activities.
3.8 Release Following the successful completion of the tasks defined in 3.3 through 3.7, above, the safety-related material and equipment will be released for continuation of construction activities.
4.0 SCHEDULE OF ACTIVITIES Attachment "D" is a bar chart which shows the tentative overall schedule for the VCP Task Force activity, grouped by Engineering disciplines responsibile for the various purchase orders.
Additionally, detailed schedules have been developed which show the estimated time durations and work flow logic for the review and disposition of discrepancies of each purchase order.
The previous Interim Report (March 23,1981) showed that the Baseline Requirements for all PO's would be completed by July 15, 1981. Because of the major redirection of the VCP Task Force effort, as exp;ained herein, and the necessity for developing and issuing new procedures to implement these changes, we have not been able to support that schedule. We now project that the Baseline Requirement activity for the 166 P0's involved will be completed as follows:
120 P0's througn August 17, 1981 33 PO's through August 18-31, 1981 7 PO's during September 1-15, 1981 6 P0's during September 16-October 15, 1981 Attachment "D" indicates that the release phase of this activity will be completed by December 31, 1981 in lieu of the estimated completion of December 1, 1981 stated in the March 23, 1981 Interim Report. This only rcfers to the disposition of any discrepancies that are identified, and not the full implementation thereof.
Every effort will be made to fully implement the dispositions by that time, but there may be hardware or documentation shortages that will be received and utilized after that date.
This schedule for release is based upon being able to substantially shorten the NUS Investigative Review phase for large-volume m .- .
Page 11 purchase orders through use of MIL-STD-1050 sampling nethods. (See 3.4,A,3 above.)
5.0 STATUS The status, as of July 31, 1981, was as follows, on the basis of 166 total purchase orders for safety-related engineered materials and equipment:
VCP Task Force Engineering:
Engineering Review Started / Completed ------------ 166/156 QA Enginering Review Started / Completed ---------- 166/166 Engr. /QA Engr. Concu rrence P.eached -------------- 101 STP Project Engineering:
Revi ed St a eted/Compl eted ------------------------ 117/ 74 investigative Review Group:
Vendor QA Program Reveiw Started / Completed ------ 161/141 Vendor Documentation Review Started / Completed --- 12/4 Final Report Generated -------------------------- 0 4
a t
.- .n. ,
Sheet 1 of 1 ATTACHMENT A ORGANIZATIONAL CHART _
- VCP TASK FORCE TASK FORCE IIANEER CONTROLS *R.
sTArr AtMINISTRATOR (COST / SCHEDULE)
(A5 REQ'D)
ENGINEERING TASK thVESTIGATIVE QUALITY ASSURANCE GROUP LEADER Review GR;k.P TASK GROUP LEADER MAhAGER J
L REVIEWING EN']NIER5/
REVIEWINGENGINEERS/ TEC*ICAL INVESTIGATIVE OuALITY REVIEW GRDUP 04 sWPORT TA5c FOR:E 6 DOC 1 MENT CENTER
= 90CLMENTAT10N GROUP l
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g-SHEET 1 0F 1 ATTACHMENT B RELATIONSHIP 0F TRD AND OTHER VCP DOCUMENTS 1
I TRD A700GP007 1
I POLICY MANUAL (TFP)
QUALITY MANAGEMENT ENGINEERING ASSURANCE INSTRUCTIONS INSTRUCTIONS INSTRUCTIONS (TFM) (TFE) .(TFQ)
All individuals performing activities covered by Instructions must have a controlled copy of those Instructions.
Uncontrolled copies of Instruttions may be distributed for infor-mation only.
ATTACHMENT C
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