ML20086S039
| ML20086S039 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/20/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-726, NUDOCS 9201030022 | |
| Download: ML20086S039 (7) | |
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ViitOINIA Hl.l:CTitle AN D l'OWIMt COhil'ANY Hirst > own,Vinuix A ununi l
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December 20, 1991 i
U. S. Nuclear Regulatory Commission Serial No. 91726 Attention: Document Control Desk NL&P/JYR Washington, D.C. -
Docket Nos. 50 338 50-339 License Nos. NPF 4 NPF 7 Gentlemen:
yJf1GINIA ELECTRIC AND POWER COMPAtO(
MpRTH ANNA PQWER STATION UNITS 1 AND 2 3
PROCUREMENT ACTIVITIES As a result of Mr. Kirspel's investigation of Nelson Electric certifications several questions arose regarding Virginia Electric and Power Company's procurement activities. Attached is a list of Mr. Kirspel's questions followed by our responses.
We hope this information will be useful in your preparation of the investigation report.
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Very trulyyours, l
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W. L. Stewart Senior Vice President - Nuclear Enclosure U.S. Nuclear Regulatory Commission cc:.
101 Marietta Street, N.W.-
Suite 2900 -
l Atlanta, GA. 30323 l
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. Mr. M. S. Lesser-NRC Senior Resident inspector i
- North Anna Power Station
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Mr. R. J. Kirspel U. S. Nuclear Regulatory Commission Office of Investigations 611 Ryan Plaza Dr.
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BESP_QBSE. TO. NRC INVESTIG ATION NELSON ELECTRIQ
_NRC QUESTlQE_1 Nelson Electric's quotation of June 3,1986, notified Virginia Power that Nelson look exception to " Nuclear Safety Related" requirements for the subject procurement.
Moreover, Nelson stated that their products were " industrial grado." and not " Nuclear Qualified" under Virginia Electric and Power Company's approved QA Program.
Why,in vlow of the above, did Virginia Power continue with this procuremenf, a weli as subsequent procurements, designated as Safety Related?
What actions did Virginia Power take to resolvo the issue of Nelson's June 1986 exception to the " Nuclear Safety Related" requirements invoked in the Virginia Power purchase orders?
RESPONSE TO QUESTION 1 Discussions with the cognizant Virginia Power Quality Assuranco specialist, as well as notes from Nelson's filos, Indicate telephone conversations took place betwoon the specialist and a Nelson Electric representative about-the subject procurement.
Virginia Power QA had received a telephone call from the Virginia Power Purchasing Department about Nelson's Quality Assuranco program and subsequently contacted the vendor. The Virginia Power QA Individual's recollection is that Nelson Electric had questions in regard to 10 CFR Part 21. A Nelson Electric representative stated that they did not accept Part 21. However, the Individual did indicate that Nelson Electric's Quality Assurance Program was approved by Virginia Power. The Virginia Power QA specialist contacted the Virginia-Power vendor surveillance. group to determine l
whether Nelson Electric's program was approved. The OA specialist in the vendor surveillance group pulled Nelson's manual and informed the specialist that Nelson's program was approved.
The Virginia Power QA specialist then wrote a note documenting the procurement to bo Safety Related, but exempting Nelson from Part 21 reporting responsibility. This i
action was consistent with procedures in effect at that time. That is, certain items were exempted from the requirements of 10 CFR Part 21 for the procurement phase, The
-items were once 'again-subject to 10 CFR Part 21 upon completion of receipt inspection when the item was placed in service. At that time, Virginia Power accepted 10 CFR Part 21 reporting responsibility when the item was placed in service.
Following instructions from the Engineering Department, the Virginia Power buyer marked the note VOlD.
Discussions with the Engineering Department reviewer, as well as notes in Nelson's.
records : Indicate telephone conversation (s) took place between the reviewing engineer and a-Nelson representative. The reviewing engineer attached a note to
' Nelson's' quotation stating: "Burt Byrne OA/OC No Problem their _OA program meets 18 criteria 10CFR50." (Note: Mr. Byrne was.emp!oyed in Nelson's Quality Assurance-department.)
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l In our judgment, the telephone conversations described above indicate an effort to resolve the issue of Nelson's exception to Nuclear Safety Related requirements shown in the quotation. The notes appear to indicate that the Virginia Power OA specialist and reviewing engineet perceived the issue to be resolved and that the exception contained in 'ho quotation referred to that one specific bid. Subsequent purchase orders to Nelson Electric continued to invoke ' Nuclear Safety Related" requirements that were accepted by Nelson. This appears to re affirm the perception that the issue had been resolved. In addition, a subsequent annual vendor evcluation performed in 1987 that included contact with the vendor, indicated that there were no significant changes to Nelson's Quality Assuraxe Manual since the initial Virginia Power survey approval.
At the time of Nelson's 1986 quotation, the various groups involved in the procurement process were separate and located in different areas within the plant site and company, Virginia Power aptemented a new procurement program In November
- 1989, The basis of the program is the NUMARC Comprehensive Procurement Initiative. Virginia Power's now procurement program integrated the procurement and materials management administrative procedures into a single source, Also, station Procurement Engineering, Purchasing, ion. Quality Assurance, and Materials Ma personnel now work at a single locat In 1986, two different groups of Quality Assurance personnel, reporting to separate managers, were involved in the procurement program Now, a single Quality Assurance manager and one Ouality group are responsible for nuclear procurement activities.
The new program establishes extensive procurement administrativo controls, requiring thorough technical reviews, and extensive quality verification checks. The program ensures that the procurement and materials management functluns comply with Virginia Power's commitments to industry standards, regulatory, and code rnquirements.
NRC QUESTION 2 Virginia Power performod a vendor survey and placed Nelson Electric on its Safety-Related Vendors List in. March 1984.
Annual evaluations of this vendor were performed in April 1985, May 1986, and April 1987.
Why was the issue of Nelson's June 1986 exception to " Nuclear. Safety Related"
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requiremento not addressed in these activities?
11ESPONSE TO QUESTION 2 Virginia Power placed Nelson Electric on the Safely Related Vendors List in 1984.-
The basis of this action was the completlon of a-vendor survey,; addressing the 18 criteria of 10CFR50, Appendix B, The survey was completed-on April.1617 at Nelson's Tulsa, Oklahoma plant by a VirgInla Power Quality Assurance auditor.
Qualhy Assurance completed annual evaluations of Nelson in April 1985,.May 1986, and April 1987, -These evaluations included the completion of a checklist by an auditor. Travel to the vendor's facility was not part of this process, A review of the 1987 evaluation report showed that:
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e The Virginia Power auditor had contacted the Nelson Quality Assurt... e Manager and requested an updated Nelson Quality Assurance Manual. The report stated that there had been no significant changes to their Manual since the initial Virginia Power survey approval. Also,the evaluation report also showed that the auditor contacted the Purchasing Supervisor at North Anna.
The supervisor said that he was not aware of any problems with past procurements from Nelson.
These comments show that the auditor addressed Nelson's Quality Assurance Program, as well as, the question of any problems with previous Nelson purchase orders.
A Nelson letter to Virginia Power, dated September 2,1988,in response to an August 1988 audit by Virginia Power states, in past, "We are in the process of updating both our internal N.P.M.'s (Nelson Procurement Manuals) and our Quality Assurance Manual to reflect our management decision not to participato in nuclear business..."
This correspondence indicates that Nelson apparently did not revise their OA Manual to reflect any changes to their Quality Assurance program until 1988.
This is consistent with the auditor's 1987 evaluation statement that there had been no significant changes to Nelson's Quality Assurance Manual, since the initial Virginia Power survey approval. The 1987 evaluation report also showed that the auditor reviewed purchase order packages for eight of the twelve purchase orders issued to Nelson since the last evaluation. However, those record packages did not indude the subject quotation. Records indicated that the quotation remained in the Purchasing Department files. Although Nelson's 1986 quotation was not addressed in the 1987 vendor avaluation, the evaluation was comprehensive in the context of the program in effect at the time.
NRC QUESTION 3 Why wasn't Part 21 invoked on the subject purchase order?
l BESPONSE TO QUESTION 3 Virginia Power's Nuclear Procurement Procedure, in effect at the time of the subject purchase, detailed the criteria for invoking 100FR21 in Purchase Order documents. It specifically stated that procurement documents for basic components (safety related) shall have the 10CFR21 appilcability statement applied except when exempted as described in a subsequent paragraph.
It also stated that a basic component is l
considered identical, by definition, to a OA Category I component; The procedure stated that certain items may be exempted from the requirements of 10CFR21 for the procurement phase. These items were once again subject to 10CFR21 after the completion of receipt inspection ahon the items were placed in service.
The applicability of, or exemption from 100FR21 for items considered to be OA Category I was to be indicated by OA Codes listed on the purchase order.
For the purchase order in question, the material supplied was OA Category I (safety l
related) and was OA Coded "AA" or "SR." These OA Codes were consistent with the
j criteria in the procedure and indicated that Virginia Power accepted responsibility of 107R21 for the itsms after completirn of receipt inspection when the items.were placed in service. At that time, it wa3 ucdeved that hese items were also supplied under Nelson Electric's approved Ovality Assurar.:,e program 'that complied w!!h the requirements of 10CFR50, Append!x S.
Under Virginia Power's new Procurement Program in effect since November 1989, 10CFR50 Appendix B requirements and the applicability of 10CFR21 are specified by i
Procurement Engineriring and clearly indicated in the purchase order documents.
Under the current program, exceptions to 10CFR21, can not be taken.
NRC QUESTION 4 Why did Virginia Power not invoke the specification?
FIESPONSE TO - QUESTION 4 Virginia Power assumed that the shop order number system used _by Nelson Electric adequately provided traceability to the original specification. The-parts ordered were -
direct replacements and were ordered by vendor part number, S!nce no part number exceptions were taken by the vendor, Virginia Power assumed that the parts were.
Identical and had traceability to the original specificaton. This assumption was in error and is not how part traceability is achieved today under cur current Procurement 4
program.
The original equipment suppl;ed by Nelson Electric under the original purchase order NA 364 was fully tots;. 'nd qualified in accordance with the original construction specification NAS at e the certified test-reports and other documentation are included in'the origM p nase order package.-
Virginia Power's enhanced procurement process, in effect since._ November 1980, requires that all the technicalf requirements, quality ' assurance requirements, and-applicable spccifications determined by procurem_ent engineering be included in the purchase order documents. The vendor is_' required to provide certification that the-items supplied are in accordance with all mentioned requirements,' Upon receipt, the items: are receipt inspected to-ensure compliancs to th.e technical and quality.
requirements, and ensure traceability is maintained. Virginla' Power normally requests the vendor ta certify that the equipment suppFed is the same as, it.not better than, and 1
interchangeable with the equipment supplied under the original purchase orde_r. The-
. vendor, under requirements'of 10 CFR 21 is obligated to notify us of any defects and non compliances to 10 CFR 21 or nnn-conformances to original declgn. The purchase orderiequires the vendor to notify ps of any revisions to their QA Program or manual.
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9 NRC QUEST 1QJLk Does Virginia Power have a copy of Nelson Electric's Quality Assurance Manual?
RESPONSE TO QUESTIOfLA No.
A review of vendor Quality Assurance manuals maintained in record.s management snowed that Nelson Electric's Quality Assurance manual has been purged from ocr files.
Virginia Fpor has committed 'o the requirements specified in ANSI N45.2.9,1974.
Sevion A.2, Procurement Records, of Appendix A of the Standard, specifies a retention time of two years for vendor Quality Assurance manuals. Periodically, our files are purged to allow room for manuals of active vendors on our Safety Related Vendors list.
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