ML20043B523
| ML20043B523 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1990 |
| From: | Potapovs U, Wilson R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20043B519 | List: |
| References | |
| REF-QA-99900401 NUDOCS 9005300149 | |
| Download: ML20043B523 (12) | |
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,1 O'RGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER WINDSOR, CONNECTICUT hu'un i INSPECTION INSPECTION NO.: 99900401/90-01 DATE: March 12-15, 1990 OH-SITE HOURS: 60 CORRESPONDENCE ADDRESS: Mr. A. E. Scherer, Vice President Nuclear Quality ABB Combustion Engineering Nuclear Power J
1000 Propect Hill Road Windsor, Connecticut 06095 ORGANIZATIONAL CONTACT: Steven A. Toelle, Manager, Operating Reactor Licensing TELEPHONE NUMBER:
(213)285-5213 NUCLEAR INDUSTRY ACTIVITY: ABB Conbustion Engineering (C-E) had NSSS contracts for 16 domestic reactors, and has support service contracts for approximately 40 reactors worldwide, C-E has support contracts to provide nuclear Replacement parts which is also a significant business area.
ASSIGNED INSPECTOR:
I J[DateO80 R. C. Wilson, Senior Reactor Engineer, Reactive InspectionSectionNo.2,(RIS-2), Vendor Inspection Branch OTHERINSPECTOR(S):
R. N. Moist, QA Specialist, RIS-2, Vendor Inspection Branch
.l-APPROVED BY:
bM g@btA/2 -.
f-lO-g o U. Potapovs, Chief, RIS-a, Vendor Inspection Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and 50 B.
SCOPE:
Review documentation and interview personnel relating to C-E's control of procurement activities.
Programmatic review was supplemented by vendor-specific reviews primarily covering purchase orders (P0s) with the following suppliers of in-core instrumentation: Whittaker Corporation Electronic Resources Division; Reuter-Stokes Canada Division of Furst Manufacturing Corporation; and Imaging and Sensing Technology Corporation.
PLANT SITE APPLICABILITY:
All C-E plants and other sites with C-E services, ff h) c 99900401
V
' ' '.x ORGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER 4 -
WINDSOR, CONNECTICUT REPORT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 2 of 12 A.
VIOLATIONS:
None B.
NONCONFORMANCE:
1.
The following examples demonstrate inadequate implementation of 10 CFR Part 50, Appendix B criteria in applying C-E Quality Specif-ication.0000-WQC-11.1, Revision D, to procurements of safety-related thermocouple cable assemblies from the Electronic Resources Division of Whittaker Corporation.
(a) Contrary to Criterion V of Appendix B and Section 6.5.1 of the C-E specification, which require that activities affecting quality must be controlled by written procedures, a silicone fluid treatment for which no written procedure existed was applied to certain electrical connectors between 1984 and 1987.
(90-01-01)
-(b) Contrary to Criterion VII of Appendix B and Section 4.1.1.1 of the C-E specification, which require a vendor program that assures quality throughout all aress of contract performance, 19 connectors were shipped in 1987 prior to submittal of
-any connector drawing for C-E review and approval.
(90-01-02) 2 C.
UNRESOLVED ITEMS:
- 1. -
After review of C-E's QA manual and procedures and discussion with C-E personnel, the inspectors were not able to conclude whether C-E requirements for audits of ASME certificate holders were consis-tent with Regulatory Guide 1.28, Revision 3 and Information Notice 86-21.
(90-01-03)
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
Unresolved item 99900401/89-01-01, control of procurement activities, I_
was reviewed.
Inspector review of C-E practices in this area resulted in the identification of Nonconformances 90-01-01 and 02. The inspector's review determined corrective actions already taken by C-E to be adequate. Therefore, the previous unresolved item and the identified nonconformances were closed during this inspection.
L 1
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ORGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER WINDSOR, CONNECTICU1
't REPORT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 3 of 12 E.
INSPECTION FINDINGS AND OTHER COMMENTS 1.
Procurement Process
,j a.
Procurement Document Control (Non-Spare parts)
The inspectors reviewed System 4 Revision 0 of the Nuclear Power Businesses (NPB) Division Nuclear Quality Assurance Manual (QAM) titled " Procurement Document Control" (PDC) and NPB Quality Assurance Procedure (QAP) 4.1, Revision 0 titled
" Preparation, Review and Approval of Purchase Orders."
-System 4 describes the controls for the preparation and issuance of procurement documents to assure that applicable requirements are addressed, and QAP 4.1 defines the pro-cedure for document control to assure that appropriate technical and quality requirements are specified.
1 C-E uses three procurement categories during the procurement process.
Category 1 pertains to safety-related items and services, Category 2 to commercial grade items which.will be upgraded for safety-related applications, and Category 3 to nonsafety-related items / services. The major focus of this inspection was on procurement Category 1.
For Category 1 procurements, a purchase requisition (PR) is written. The PR, which becomes a procurement package,.
includes the following:
statement of the scope of work to be performed, technical requirements, quality class and QA program, 10 CFR Part 21 requirements, documentation require-ments, nonconformance, proprietary information, and! release status. When required, an independent technical reviewer reviews the procurement package to verify that the order includes appropriate technical requirements. After resolu-tion of any comments the independent reviewer annotates the l
PR, which completes the design quality requirements of the document. Then a Nuclear Quality System (NQS) representa--
tive performs a quality verification of the document. The t
NQS representative adds infonnation to the document such as:
the supplier's QA manual and revision level approved for use, methods to be used to accept the item or service, whether or not the item will be drop shipped, receiving inspection at C-E, and witness hold points or integrated f
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l i-ORGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER WINDSOR, CONNECTICVT 1
REPORT' INSPECTION
- NO.: 99900401/90-01 RESULTS:
PAGE 4 of.12 i
L manufacturing quality plan (IMQP) if required for in-protess surveillance. After completion of this review and resolution-of any comments the NQS representative annotates the PR, which i
then signifies that the quality requirements have been completed
'~
for the PR.
1 The project manager then reviews the PR for administrative l
compliance with customer requirements and authorization for procurement. After all the required reviews, the purchasing agent issues a PO to the approved supplier. Documents used to control the technical interface are the Technical Change Request (TCR),DeviationfromContractRe L
theRequestforApprovalandReview(RAR)quirements(DCR)and Changes to the C
procurement documents are controlled by requisition supplements which are subject to the same degree of control as used in preparation of original documents..The L
inspectors. reviewed several procurement packages issued to Whittaker Corporation, Electric Resources Division; Reuter-Stokes Cana<ia; and Imaging and Sensing Technology Corporation to verify implementation of the procurement program..The inspectors verified that C-E customer requirements were passed on in the P0's to C-E suppliers.
b.
Procurement Document Control (Spare Parts)
The inspectors reviewed System 4.0, Rev.1 of Nuclear Spare-t Parts (NSP) Quality Assurance Program Description-(QAPD) titled " Procurement Document Control." System 4.0 describes procurenent document preparation, review and change control
-to assure that appropriate technical and quality r@uire-ments are specified. The procurement process is essentially the same as for non-spare parts except for a few minor changes. -The spare parts program uses an Order Processing and Management Information System (OPMIS), which serves as the basis for electronic P0 preparation and processing.
OPMIS also provides a secure method for prep (NSPDB), and for aring nuclear spare parts orders using the NSP Data Base obtaining required approvals prior to release of final procurement documents. The following guidance is used when determining the appropriate methods for parts acceptance:
(a) documentation reviews, for items-of simple design involving standard materials, processes and tests, or when l
the part is being supplied by the original equipment i
N
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.i
. '0RGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER i
+
WINDSOR, CONNECTICUT j
(
REPORT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 5 of 12 manufacturer and history indicates satisfactory performance; j'
(b) source verification; or (c) drop shipment / receiving inspection, only when the item is relatively simple or i
standard in design and quality characteristics can be checked after receipt. The NSPDB establishes Category 1 technical and quality requirements for warehouse stocking of items, since customer requirements are not known. The inspectors reviewed five C-E customer PO's (Northeast Utilities, Florida Power and Light, Baltimore Gas and Electric, Arizona Power and Light, and Alabama Power Company) and' verified that the technical and quality requirements were included in C-E supplier P0's.
c.
Approved Suppliers List The inspectors reviewed NPB QAP 7.2, Revision 0 titled
" Approved Suppliers List" (ASL). QAP 7.2 defines the method used by C-E to >repare and maintain a list of companies and organizations w1ich have been formally approved for supply of materials, items and services to NPB. The Manager.
Supplier Control has. principal responsibility for imple-mentation of QAP 7.2.
The inspectors reviewed C-E's basis for addition, removal and extensions of suppliers as part of the maintenance of the-ASL. Suppliers are placed and main-tained on C-E's ASL if they hold a current ASME certificate for the items procured, if C-E's customer directs them to use a specific supplier (not applicable to ASME suppliers), or if they have been evaluated and approved by C-E Quality Opera-tions. During this inspection the inspectors reviewed several P0's and verified that the suppliers were on the C-E ASL.
d.
Control of Purchased Items and Services The inspectors-reviewed the procedures listed belnw:
NPB, NQAM, System 7, Revision 0 Control cf Purchased Items and Services NPB, NQAM, System 18, Revision 0 Audits NSP, QAPD, System 7, Revision 1 Control of Purchased Items and Services
F J
Mjm ORGANIZATION:L~ABB-COMBUSTION ENGINEERING NUCLEAR POWER m
WINDSOR,_ CONNECTICUT REPORT INSPECTION NO.:. 99900401/90-01 RESULTS:
PAGE 6 of 12 NPB, QAP 7.1, Revision 0 Supplier Evaluation --
and Approval-4 NPB QAP 7.3, Revision 0 Control of Suppliers DocumentorReview(RAR):
Process NPB, QAP 7.4, Revision 0 Control of Supplier 1
Nonconformances Deviation From Contract ~ Require-ments-(DCR) Process e
NPB, QAP 7.6, Revision 1 Source Surveillance NPB, QAP 18.2, Revision 2 Supplier Audits l
The inspectors reviewed C-E's procurement,and materials QA 3
program for the evaluation and control of supplier quality i
performance for safety-related materials and services.
l L
_C-E's Quality Operations group has the responsibility for
[
evaluating suppliers to ensure that they have the facilities,.
j l
QA program, personnel and equipment to supply safety-_related i
items and services.
Suppliers of safety-related items or i
services are-required to implement a QA program in accord-l ance with 10 CFR Part 50, Appendix B, as applicable to the i
L scope of work performed.
C-E ensures the capability of suppliers of safety-related items by in-facility pre-award surveys, ASME certificates, QA program audits, historical
-l
. records, annual evaluations, and triennial implementation audits.
i.'
One area of concern was the way C-E utilized ASME surveys of certificate holders. NRCInformationNotice(IN)86-21,
" Recognition of ASME Program for N stamp holders," dated i
March 21, 1986, recognizes that if ASME has surveyed the i
supplier and issued a certificate of authorization of appropriate scope, then the supplier may be placed on an i
ASL.
However, this recognition applies only to the programmatic aspects of the ASME accreditation program and C-E is still responsible for ensuring that the supplier is 1
effectively implementing its approved QA program.
C-E's i
interpretation appears to be inconsistent with IN 86-21 based on conversation with C-E personnel, but their practice of conducting source evaluations appears to be I
l A
,a w
ORGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER 3
WINDSOR, CONNECTICUT-REPORT-INSPECTION.
NO.: 99900401/90-01 RESULTSi PAGE 7 of 12 appropriate. C-E contends' that Regulatory Guide 1.28,
- Revision 3, dated August 1985, paragraph 3.2 does not require C-E to audit ASME certificate holders on a triennial basis as long as ASME is auditing the supplier.
- However, the NRC inspectors stated that the programmatic audits being performed by ASME' can only be used as supporting documentation to keep the supplier on the C-E ASL. There still are require-ments for the implementation survey or audit, and'for
~
subsequent implementation or source audits for ASME suppliers
- to be consistent with IN 86-21.
C-E-further stated that C-E performs a source surveillance inspection when a P0 is awarded to an ASME supplier.
C-E internal procedures appear to be contradictory in that NPB NQAM System 4 Paragraph 2.1.2b states that " suppliers who have ASME Certificates of Authorization or Quality Systems Certificates (materials) may be.used without survey or audit by NPB or their subcon-tractors for the items contained in the scope of their-
- certificates," while NPB NQAM System 7 Paragraph 2.3.1 relating to supplier pre-award evaluations states that "ASME
- Section III material manufacturers / suppliers shall be evaluated and qualified based upon appropriate requirements in ASME code Article NCA-3800. The evaluations shall include.a review of the supplier's QA program manual, including supporting procedures as appropriate, and a survey-to verify implementation at the location of work." Based upon the discussions and the apparent inconsistencies in procedures, this concern is designated unresolved item 90-01-03,'Section C of this report.
The inspectors selected the ASME suppliers listed below for i
review of source surveillance inspection reports.
Cajon Company Copes Vulcan Target Rock Ranor locorporation Pacific Pumps / Dresser Only two of the five suppliers had any activity (Target Rock &
Copes Vulcan). The inspectors reviewed two source surveillance reports for inspections conducted by C-E at Target Rock during the 1984 - 1985 timeframe and one C-E source surveillance inspection repcrt for Copes Vulcan during 1978. The surveillances consisted of testing and
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,y ORGANIZATION:
ABB-COMBUSTION ENGINEERING NUCLEAR POWER 1
-WINDSOR,_ CONNECTICUT j
REPORT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 8 of 12-
-visual inspection of the products. No anomalies were nered iduring this review.
1 The inspectors reviewed in detail documents for two safety-related suppliers,.Whittaker Corporation and Reuter-Stokes Canada..The Whittaker Corporation audit reports and annual evaluations were reviewed for the 1976-1990 timeframe and
,l Reuter-Stokes Canada for the 1971-1990 timeframe. The inspectors verified that initial supplier implementation audits, annual reviews, and subsequent audits were per-formed, as applicable; that documented objective evidence was identified in the audit reports and checklists to verify that an implementation audit was-performed; and that'
. supplier surveillances were performed when required. The anomalies identified during these audits were generally programmatic and did not affect the product. However, a major 1988 performance-based audit of Whittaker identified product-related anomalies. The inspectors reviewed
-]
Whittaker's responses to the 1988 audit. A supplier evaluation summary, dated February 7, 1990, was reviewed in which C-E accepted the revised Whittaker Corporation QA.
Manual. This evaluation also placed Whittaker on C-E's ASL as conditionally approved for supply of QC-1 electrical components and assemblies (e.g., mineral insulated cable, connectors, cable assemblies, heated junction. thermocouple probes). C-E _ indicated that Whittaker's status may be upgraded to unconditional _ upon satisfactory completion of QA program implementation verification as determined by future 1
C-E audits.
It was estimated that Whittaker Corporation will complete ' sufficient work under their revised QA program j
by May 1990 to allow C-E to schedule implementation audits.
During annual evaluations, C-E reviews the supplier's Quality Assurance Manual, past purchase orders, receiving inspections. reports, DCR's, Field Action Reports, Corrective Action Reports, supplier's file for_ any restrictions, NRC IN's and Bulletins, past audit /
outstanding QA finding reports) pre-award surveys (for
, and past source sur-veillance inspection reports.
C-E's audit process appeared to be satisfactory.
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'. ' ORGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER WINDSOR, CONNECTICUT REPORT =
lHSPECTION NO.:. 99900401/90-01 RESULTS:
PAGE 9 of 12 j
e.
Dedication of Commercial Grade Equipment C-E has engineering'and QA groups devoted to the growing
. spare parts business. C-E briefly described the spare parts procurement program for QC Category 2 parts -- commercial grade. parts intended to be dedicated for safety-related use by the licensee customer. C-E provides a " designation" process intended to facilitate future dedication for the specific end-use application. Critical characteristics are included in the program, often functional in nature.
Previous Inspection Follow-up 2..
Two NRC inspection reports addressed concerns related to C-E procurements from the Electronic Resources Division of Whittaker Corporation: 99900401/89-01 covering a May 22-25, 1989 inspection of C-E, and 99901164/89-01 covering a June 20-22, 1989 inspection of Whittaker.. Unresolved ~1 tem 99900401/89-01-01 covering C-E's control of procurement activities was identified as a result of those inspections. The two specific concerns are o
summarized in Section E.3 of the Whittaker inspection report; they-involve a silicone treatment process that was used without i.,
procedural control, and 19 connectors that were shipped prior to drawing review and approval by C-E.
The inspectors examined L
additional' records and interviewed personnel at C-E concerning l.
these areas as part of the inspection of C-E's procurement controls.
t
[
For the connectors procured in 1987 on PO 9770018-71186, the P0 t
L originally specified an existing Whittaker connector design by part number, and specified a modified rear sleeve. A new Whittaker drawing was generated, and a P0 supplement was initiated specifying the part number covered by the new drawing.
The next day, prior to submittal of the new drawing, C-E approved shipment of 19 connectors. When the new drawing was submitted, C-E noted that the method of ground connection was different than originally specified and requested a change.
The new drawing was then revised, and five connectors were built
)
to the approval revision and shipped. Thus 19 connectors were L'
built.to the unapproved drawing with a ground contact crimp sleeve, and 5 were built to the approved revision without the l
I
. Y, ORGANIZATION: ABB COMBUSTION ENGINEERING NilCl. EAR POWER WINDSOR, CONNECTICUT p.
t rep 0RT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 10 of 12 sleeve. The discrepancy was discovered by a third party to wHtim the connectors were sent for additional assembly work, prior to delivery to the user. The 5 connectors were then modified or replaced so that all 24 were alike. The inspectors also noted that the 19 connectors were inspected and shipped shortly after Whittaker's facilities were relocated. This event appears to be an isolated incident of breakdown of C-E's procurement control systemt no similar occurrence was found by the inspectors. The event, however, exemplifies deficiencies discovered in C E's May 1988 audit of Whittaker with respect to inadequate procedural controls.
The silicone. treatment process concern is addressed in detail in the Whittaker inspection report, 99901164/89-01.
Briefly, the treatment was applied to connector headers with low insulation resistance.
It was employed on connectors built for C-E from 1984 to 1987, and was considered proprietary.
However, no written procedure was prepared until April 1987.
Report 99901164/89-01 addressed the impact of the silicone treatment process on the environmental qualification (EQ) of the con-nectors, and concluded that the possibility of an EQ concern is remote.
(referenceNonconformance 90-01-01 end 02) a.
Environmental Qualification During the present inspecMon the NRC inspec iors focused on whether the cumulative eff ect of multiple 4.4 deficiencies jeopardizes the EQ of cable and connector assemblies built since the EQ type test specimens were made in 1984; that is, are the 1984 type test specimens truly representative of subsequent production equipment'l In November 1984, C-E conducted a technical and QA audit of Whittaker's design and process operations for newly-developedheatedjunctionthermocouple(HJTC) assemblies.
The technical audit report covers areas very similar to findings in the May 1988 C-E audit, which are also con-sistent A th the 1989 NRC inspection of Whittaker and C.E.
The defickAcies are primarily related to documents rather than to hardware. Taking into account also the numerous other C-E audits and surveillances reviewed by the NRC inspectors, hardware concerns appear to have been of three types:
small errors in assembly overall lengths, reversed i
ORGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER WINDSOR, CONNECTICUT REPORT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 11 of 12 connector pin assignments, and the connector ground sleev,e concern addressed above. The existence of these concerns and the absence of others reflect a consistent pattern of production personnel building a product with high basic integrity but with defects in application-specific characteristics typical of inadequate production controls.
Product quality over the time span in question appears to derive from the skill of the workers more than from an ongoing control system. Even for the types of defects noted, only the connector ground sleeve concern was undetected, causing shipment of discrepant hardware. The relatively simple nature of the product (almost no moving parts)..the long history of aerospace use of the proprietary product, and the care exercised by C-E in qualifying the nuclear products (especially the new HJTC's) all con-tribute to the conclusion that environmental qualification remains acceptable, b.
Nonconformance Unresolved item 99900401/89-01-01 is now classed as Noncon-formance 99900401/90-01-01 and 02 described in Section B.1 of this report. The noted examples were corrected in 1987 and 1988. Significant actions to prevent recurrence are cited in the 1989 NRC inspection reports. During this inspection the NRC inspectors reviewed C-E's Suppliers Evaluation Summary and Supplier Evaluation Checklist for Revision L of Whittaker's QA manual. Based on these evaluations on February 7, 1990, C-E accepted the revised QA manual and designated Whittaker as a conditionally approved supplier.
Isplementation audits are expected in mid-1990.
In view of the actions taken by C-E and Whittaker, the nonconformances are considered closed during this inspection.
F.
PERSONS CONTRACTED:
- + A. E. Scherer, Director, Nucicar Licensing
- + S. A. Toelle, Manager, Operating Reactor Licensing
- + J. M. Betancourt, Senior Consultant, Licensing
- + R. J. Fitzgerald, Director, Quality Operations
- + D. L. Levan, Manager, Supplier Evaluation R. W. Driscoll, Senior Engineer, Quality Operations a
GRGANIZATION: ABB-COMBUSTION ENGINEERING NUCLEAR POWER WINDSOR, CONNECTICUT REPORT INSPECTION NO.: 99900401/90-01 RESULTS:
PAGE 12 of 12 R. F. Ryan, Senior Engineer, Quality Operations M. W. Stewart, Supervisor, Spare Parts QA S. L. Mara, Senior Engineer, Qualit/ Operations A. J. Kostenko, Senior Engineer, Quality Operations
+ J, P. Pasquenza, Manager, Quality Programs 1
C. B. Fowler, Supervisor, Quality Programs J. M. Burger, Manager, Reactor Mechanical Systems M. J. Linden, Senior Engineer, Reactor Mechanical Systems
- + J. E. McConnell, Manager, Nuclear Spare Parts T. S. Bernard, Supervisor Technical Support (Spare Parts)
\\
P. A. Hellandbrand, Engineer, Spare Parts C. Keefer, Engineer, Spare Parts
- + M. J. Sponza, Engineer, Spare Parts t
- Attended entrance meeting on March 12, 1990
+ Attended exit meeting on March 15, 1990 e'
_ _ _