ML20135E635

Insp Rept 99901306/96-01 on 960909-12 & 1028-31. Noncompliance Noted.Major Areas Inspected:Reviewed Activities Associated with Implementation of Selected Portions of Quality Assurance Program & Licensee Monitoring

ML20135E635
Person / Time
Issue date:	12/04/1996
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20135E595	List: ML20135E592 ML20135E612 ML20135E635
References
REF-QA-99901306 99901306-96-01, 99901306-96-1, NUDOCS 9612110378
Download: ML20135E635 (8)

Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Report No: 99901306/96-01 Organization: ABB-Combustion Engineering

Contact:

Ronald J. Fitzgerald, Director Quality Assurance ,

860/285-9816 i

Nuclear Industry Instrumentation and control systems and Activity: associated spare and replacement parts Dates: September 9-12 and October 28-31, 1996 Inspectors: Anil S. Gautam, Senior Engineer Frank Gee, Electrical Engineer Approved by: Gregory C. Cwalina, Chief Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs l

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l 9612110378 961204 Enclosure 2 PDR GA999 EMVC-E 99901306 PDR

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1 INSPECTION

SUMMARY

During this inspection, the NRC inspectors reviewed activities associated with implementation of selected portions of ABB-Combustion Engineering's (ABB-CE's) quality assurance (QA) program and licensee monitoring of ABB-CE's control of p quality.

The inspection bases were as follows:  :

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• Appendix B, " Quality Assurance Critcria fo* Nuclear Power Plants and fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reaulations (10 CFR Part 50).

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• 10 CFR Part 21, " Reporting of Defects and Noncompliance."

l NRC Regulatory Guide 1.144, " Auditing of Quality Assurance Programs for Nuclear Power Plants."

ABB-CE's Quality Assurance Manual (QAM) 100, Revision 4, dated May 1, l 1996, and associated implementing procedures.

The inspectors noted one instance in which ABB-CE failed to conform to NRC requirements imposed upon it by NRC licensees. This nonconformance is discussed in Section 3.1 of this report.

2 STATUS OF PREVIOUS INSPECTION FINDINGS Nonconformance 99900538/95-02-01 (CLOSED)

Contrary to Criterion V of Appendix B to 10 CFR Part 50, and paragraph D.2 of ABB-CE. Nuclear Operations " Administrative Procedure for Reporting Defects and Noncompliance," dated February 28, 1996, ABB-CE did not document its screening of potential Part 21 issues.

l ABB-CE responded to the notice of nonconformance (NON) by letter of April 26, 1996, stating that it would make appropriate changes to its Part 21 implementing procedure. ABB-CE " Procedure for Evaluating and Reporting of Defects and Noncompliance Pursuant to 10 CFR Part 21," dated September 30, 1996, addressed the process of screening and reporting of potential Part 21 issues by all Nuclear Systems and Nuclear Operations employees.

The procedure requires each deviation or potential failure * ) comply to be evaluated, the evaluation documented, and the disposition recorded.

The inspectors found the revised procedure acceptable.

3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Ouality Assurance Proaram

a. Insract' ion Scope The inspectors examined ABB-CE's QA program, policy, implementing procedures, conformance to procurement documents, corrective actions in 2

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response to licensee audit findings, commercial-grade item dedication, Part 21 evaluations, and monitoring of subvendors, i

b. Observations and Findinas l

ABB-CE's nuclear operations comprised five business units, including Total Quality, Engineering, Field Services, Fuel Operations, and Technology Development. Each business unit was monitored by quality i control (QC) inspectors. The QA staff comprised the QA director and four QA managers. The QA director reported to the Vice President of Total l

Quality who reported to the President of Nuclear Operations. The l inspector observed that QAM-100 System 1, Figure 1.2, indicated that the QC inspectors reported to the management of the individual business units rather than to QA. The QA management stated that irrespective of the QAM-100 chart, the QC inspectors were monitored by QA.

The inspector witnessed, in part, testing of a safety-related core cooling monitoring system for Millstone Unit 2 and observed equipment l being subjected to various inputs to validate system performance and  !

conformance to licensee procurement specifications. No concerns were identified.

The inspector evaluated ABB-CE's audit reports EM-9605 and EM-9606, dated August 28, 1996, of its subvendor ABB-EM and determined that the audit reports did not provide adequate objective evidence of quality furnished l by the subvendor. For example, the reports did not address compliance with Appendix B criteria, internal audit findings and corrective actions, I negative observations or weaknesses, and any deficiencies identified by other customers. ABB-CE's QAM-100, System 7.0, Section 2.5.4, " Control 1 of Purchased Items and Services," Revision 2, requires, in part, that the '

assessment of the overall quality performance of its suppliers of safety-related items shall include consideration of reports of audits from other sources (i.e., customers, the U.S. Nuclear regulatory Commission ~(NRC),

other ABB nuclear groups). During 1995-1996, Rochester Gas & Electric Company (RG&E) and Niagara Mohawk Power (NMP) Corporation, purchased instrumentation directly from ABB-EM and identified problems with ABB-EM's commercial-grade dedication of safety-related instrumentation components. Licensee findings included ABB-EM's failure to identify or test critical characteristics of test jacks, diodes, and other printed circuit board (PCB) components. ABB-CE's lack of consideration of licensee fSdings precluded it from assessing whether ABB-EM provided reasonable assurance that dedicated items will perform their intended safety function. This practice constitutes Nonconformance 99901306/96-01-01. The QA manager stated that the ABB-CE audit reports of ABB-EM were not typical and that QA planned to include additional details in its future audit reports.

During 1993-1996, ABB-CE purchased safety-related instrumentation from ABB-EM for' sale to licensees. ABB-EM purchased these items as commercial-grade and dedicated them for safety-related applications.

During the NRC inspection on September 9-12, 1996, ABB-CE could not provide the inspector sufficient documentation to demonstrate that 3

selectcd items were qualified to perform their safety functions. During the inspection on October 28-31, 1996, two inspectors visited the ABB-CE (Windsor, Connecticut) and ABB-EM (New Britain, Connecticut) facilities to further assess commercial-grade dedication of selected safety-related instrumentation. The inspectors assessed selected purchase orders (P0s),

procedures, licensee surveillance, design drawings and documentation pertinent to commercial-grade dedication activities. The following ABB-CE P0s to ABB-EM and associated items were examined:

P_Q1 ITEMS 404676 PCB 406610 Relay 406260 Relay and operational amplifier 405516 Switch 404700 Variable set-point card 404489 Test jack 405651 PCB 405842 Card assembly for combinational circuit 9607145 Fiber optic switch 9405001 Repair of bistable trip unit 9503180 Diagnostic testing of setpoint card Upon the basis of commercial-grade dedication documents, the inspectors determined that ABB-CE and ABB-EM reviewed safety functions, identified appropriate critical characteristics, and performed tests and analyses to ,

dedicate the aforementioned items. No concerns were identified. l The inspector reviewed Part 21 reports issued by ABB-CE for design errors or failures during the past 3 years. The inspector observed that nonconformance reports (NCRs) did not address Part 21 screening, applicability, and reportability, and there was no mandatory training for the staff on Part 21 programmatic activities. This concern was also  ;

identified in a previous inspection (see Inspection Report 99900538/95- i 02). In response to these concerns, ABB-CE revised its Part 21  !

implementing procedure to address documentation of screening on QA forms l (including noncompliance forms), and self-study QA training for employees )

(see Section 2 of this report).

The inspector examined a summary of 1993-1996 NCRs concerning instrumentation and observed no trending of failures by QA to evaluate root causes in order to prevent recurrence of failures. The QA director provided evidence that an initiative was in place to improve trending of failures and expected it to be implemented by about January 1997.

The inspector observed that there was no sharing of Part 21 information, subvendor audits, or hardware problems among ABB-CE and other ABB companies. For example, ABB-CE purchased items from ABB-Transmission and Distribution (ABB-T&D) but was not aware of failures of type MG-6 electrically reset latching relays (documented in NRC Report 50-280/96-05 and 50-281/96-05, dated July 15, 1996). The QA manager stated that ABB-CE had not purchased the MG-6 relay, but that ABB-CE planned to expand the scope of its questions during subvendor audits.

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The inspector observed two unmarked boxes in the holding area for safety-related items and asked whether the boxes contained any non-safety parts that could compromise the segregation of safety-related parts. The QC inspector examined the boxes and confirmed that the shipping boxes contained safety-related parts and that the storage area was controlled by receipt inspection and restricted access.

c. Conclusions l

The inspectors concluded that, 11 general, the QA manual, work l instructions, and procedures were adequate, except for the nonconformance and screening of potential Part 21 issues described herein.

3.2 Review of Monitorina of ABB-CE by Licensees  !

a. Inspection Scope The inspector evaluated licensee monitoring of ABB-CE's control of quality for safety-related items purchased by licensees, including audits and surveillances of ABB-CE's commercial-grade dedication, Part 21 reports, and monitoring of subvendors.

b. Observations and Findinas The inspector contacted the Nuclear Utilities Procurement Issues Committee (NUPIC) audit team leaders and selected licensees to discuss scope and findings of the audits and surveillance.

NUPIC audited ABB-CE in October 1993 and October 1995. Utilities represented on the NUPIC audit teams included Arizona Public Service (APS) Company, Baltimore Gas & Electric Company, Consolidated Edison Company, Consumers Power Company, Entergy Operations (EO), Florida Power and Light (FP&L) Company, Illinois Power Company, Northeast Utilities, Pennsylvania Power & Light Company, Rochester Gas & Electric Corporation (RG&E), Union Electric Company, Virginia Electric & Power Company, Washington Public Power Supply System, and Yankee Atomic Electric Company, NUPIC's 1993 audit identified a finding concerning ABB-CE's failure to identify critical characteristics of certain commercial-grade items during ABB-CE's dedication of irstrumentation and control items. In ,

response to this finding, ABB-CE developed p P e No. 00000-ICE-0509,  !

" Technical Guidelines for Commercial-Grade Dedication," to require identification of critical characteristics and specify form, fit, and function of dedicated items. The NUPIC team also identified a finding  ;

concerning ABB-CE's failure to use an approved vendor for calibration of measuring and test equipment (M&TE). The NUPIC audit team accepted ABB- l CE's corrective actions. '

NUPIC's October 1995 audit identified findings concerning deficiencies in ABB-CE's monitoring of subvendors, design calculation packages, and control of M&TE. ABB-CE's monitoring of its subvendor MTS Systems  !

Corporation (supplier of calibration services) was deficient in that ABB- i CE did not verify whether MTS implemented its out-of-tolerance- I 5

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l notification program, established integrity of traceability documentation, or performed internal audits. NUPIC accepted ABB-CE's j corrective actions.

APS audited ABB-CE in March 1995. The APS audit identified several weaknesses in ABB-CE's implementation of its design control program including documenting design assumptions, identifying design interfaces between ABB-CE and APS engineering, verifying and identifying software, controlling computer output documentation, and maintaining QA records in Chattanooga, Tennessee. ABB-CE is i n the process of resolving the findings.

FP&L audited ABB-CE in June 1995. The FP&L audit identified findings concerning ABB-CE's failure to monitor the adequacy of the design control activities conducted by its subvendor, and ABB-CE's basing its engineering judgments on unverified design inputs. FP&L accepted ABB-CE's corrective actions for these findings.

Based on FP&L surveillance reports 08.06.CEPSG.94.1, 95.1, 95.5, and 96.1, FP&L conducted effective surveillances of ABB-CE and ABB-EM.

Activities monitored included commercial-grade dedication activities (review of critical characteristics and verification), nonconformances, and M&TE calibration data.

Discussions with E0 and Southern California Edison procurement staff determined that they relied on NUPIC's audit for monitoring ASB-CE and did not conduct any surveillance of ABB-EM.

The inspector determined that NUPic and the licensees did not audit the subvendor ABB-EM. Further, NUPIC and licensee's audits of ABB-CE did not identify that ABB-CE performed inarlequate audits of ABB-EM (see section 3.1.b of this report).

The inspectors observed that licensees, in general, did not identify specific safety functions of spare parts purchased from ABB-CE. P0s identified spare part numbers and pertinent systems, not pertinent instrumentation circuits or parameters monitored. ABB-CE stated that they did not ask licensees to identify specific safety functions, rather qualified the spare parts to the original design of the system. Lack of identification of specific safety functions by licensees could result in inadvertent misapplication of procured items.

c. Conclusions In general, licensees audited ABB-CE in accordance with proper criteria, procedures, and checklists. Licensee monitoring of ABB-CE's QA program for instrumentation components was not always adequate: licensee audits did not ensure that ABB-CE was controlling the quality of their purchased itera from ABB-EM.

4 j 3.3 Entrance and Exit Meetinas In the entrance meeting on September 9, 1996, the NRC inspector discussed the scope of the inspection, outlined the areas to be inspected, and

established interactions with ABB-CE management. In the exit meetings on September 12 and October 31, 1996, the inspectors discussed their findings and observations.

4 PERSONNEL CONTACTED ABB-CE Don Allen, Vice President, Total Quality l

Ron Fitzgerald, Director, QA Mark Stewart, QA '

ll Gary Bloomquist, Manager, Q"ality Programs and Procedures  !

Richard Bradshaw, Manager, Instrumentation & Controls Engineering (ICEE) i Robert Driscoll, Supplier Audits Edward Stepaneck, QC Inspector, ICEE Assurance i 2

Ian Richard, Manager, Operations Licensing l Charles Molnar, Licensing Engineer l Paul Rohan, Total Quality '

Mark Stewart, Supervisor, Spare parts QC Kenneth Tomany, ICEE QC  ;

Marty Ryan, ICEE l Larry Bryan, Procurement Engineer, Nucle;r Spare parts  !

ABB-Electro Mechanics '

i William Hadovski, Engineering Manager  !

Alex Oja, Contract Manager William Wayland, Supervisor, QA Engineering Edward Rollins, Plant Manager K.Parekh, Senior Engineer M.J. Merlini, Contract Administrator Licensees (contacted by telephone)

Mike Liley, QA Manager, RG&E Company Wallace Woodard, Principal Engineer, FP&L Company Olga Hanek, Lic nsing Engineer, FP&L Company George Kuhn, Procurement Engineer, FP&L Company Robert Ripley, 1993 NUPIC Team Leader, Union Electric Company Ron Casavant, 1995 NUPIC Team Leader, Washington Public Power Supply System Derek fiercurio, Licensing, Southern California Edisen Company Joel Rachal, Procurement Engineer, E0 7

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 99901306/96-01-01 NON Failure to assess subvendor's control of quality Closed 99900538/95-02-01 NON Inadequate Part 21 screening process by )

ABB-CE l

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