ML20155B886
| ML20155B886 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/1988 |
| From: | Haass W, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20155B885 | List: |
| References | |
| REF-QA-99900505 NUDOCS 8810070123 | |
| Download: ML20155B886 (10) | |
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ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION INSPECTION NO.: 99900505/88-01 DATE: August 3-5, 1988 ON-SITE HOURS: 46
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CORRESPONDENCE ADDRESS: Mr. Charles R. Healy, Director Quality Assurance Ebasco Services, Incorporated Two World Trade Center New York, New York 10048 ORGANIZATIONAL CONTACT: Mr. Sal Sparacino, Manager, QA Engineering TELEPHONE NUMBER: 212-839-2457 -
NUCLEAR INDUSTRY ACTIVITY: Design, procurement, and quality assurance activities for several nuclear projects.
i ASSIGNED INSPECTOR: (L k dw /87 W. P. Haass, Special Projects Inspection Section Date OTHER INSPECTOR: R. t . Pettis , Jr. SPIS 3f APPROVED BY: M.I W 9*26' N U. Potapovs. Chief, dPIS, Vendor Inspection Branch Date Ik5PECTION BASES AhD SCOPE:
A. BASES: 10 CFR Part 50, Appendix B, and Ebasco Topical Report ETR-1001 l "Nuclear Quality Assurance Program Manual."
! B. SCOPE _:
Review records and procedures and interview personnel regarding I
approved vendor lists, vendor evaluation audits, qualification of auditors, and licensee audits to detemine the validity of allegations identified by a forcer Ebasco employee, i
l PLANT SITE APPLICABILITY: Waterford SES (50-382) 8310070123 080928 l PDR OA999 EECEBAS 99900505 F0C
ORGAhlZAT10N: EBASCO SERVICES INCORPORATED .
. NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/88-01 RESULTS: PAGE 2 of 10 BACKGROUND:
This inspection was prompted by a complaint of discrimination filed with the Deportment of Labor (DOL) by a former Ebasco employee and referred to NRC. The complaint includes an allegation that Ebasco had violated 10 CFR 50 Appendix B and its internal procedures in the evaluation and approval of certain material and component suppliers for the Waterford SES. Specifically, the alleger claims that certain suppliers were found unsatisfactary for supplying safety-related components and materials in the 1981-83 timeframe.
Further, the alleger clails, because Ebasco had already placed purchase orders with these suppliers and any delays could impact unfavorably on the Waterford construction schedule, Ebasco sent other unqualified auditors to evaluate these suppliers who found them to be satisfactory. In essence,
, the alleger claims Ebasco was falsifying the qualification of suppliers and, as a result, items are now installed at Waterford that were provided by unquelified suppliers.
To determine the validity of the above allegation, an inspection was conducted at the Ebasco offices to review the pertinent records and related procedures.
Imediately prior to' the inspection, the NRC inspectors met with the alleger to identify more clearly the specific records and areas of concern. Each area of concern anc related matters are discussed in the following sections of this report.
VIOLATIONS:
None NONCONFORMANCES:
None ,
FINDINGS AND COMMENTS:
- 1. Approved Vendors List It was alleged that Ebasco maintained a "supplementary aporoved supplier list" that included vendors who could not be approved due ;o the lack of an Appendix B quality assurance program. However, due to the exigencies of the construction schedule, these vendors were nevertheless utilized to provide safety-related components and materials for the Waterford project.
The inspecturs reviewed the Ebasco files that contained the lists of vendors for the Waterford pruject, it was determined that Ebasco
ORGANIZATION: EBASCO SERVICES INCORPORATED ~
- NEW YORK, NEW YORK REPORT INSPECTION RESULTS: PAGE 3 of 10 NO.: 99900505/88-01 maintained two such lists; one list was called the corporate Approved Vendors List (AVL) which contained those vendors that were utilized generically for several projects. The cost of performing audits of these vendors was shared by the several projects that utilized them.
The second list was the Waterford-3 List which contained the vendors that were unique to the Waterford project. This list also included vendors recomended by the' licensee, Louisiana Power and Light Company (LP&L), based on successful past and anticipated future procurement relationships. Both lists were issued generally on a quarterly basis in accordance with an internal distribution list. The introduction to both lists indicated that the vendors had been evaluated and determineo to have QA programs satisfying the requirements of 10 CFR 50 Appendix B and were therefore qualified to provide safety-related components and materials. All vendors evaluations were perfornied by personnel from the QA Department located in Ebasco's New York City offices.
To further assess the acceptability of the vendors on the Waterford-3 List, the inspector selected several vendors from the list and reviewed their evaluation records. The vendors selected were Rotohammer, Conduit, Picoma, Wheatland Tube, Guyon, and Bergen-Patterson. The records indicated that all vendors were adequately evaluated and approved for supplying safety-related items.
In sumary, although it seemed unusual to maintain two AVLs for a project, there were logical reasons for this approach, and no instances were found in which unqualified vendors were placed on either list.
- 2. Use of Ebasco Specifications in Lieu of Appendix B The alleger indicated that, in some instances, due to a lack of con-formance to 10 CFR 50 Appendix B requirements, vendors were evaluated against the Ebasco specification referenced in the purchase order rather than Appendix B.
The inspectors found that, in several instances the vendor was eval-uated against the Ebasco specification; however, based on the review of several Ebasco specifications referenced in the vendor evaluation audit reports, these specifications in turn called for compliance with Appendix B either directly or by referencing another specifica-tion. The speciftcotions reviewed incluoed LOU 1564.124F; LOV 1564.068; LOU 1564.403; and LOU 1564.270. For example, specification LOU 1564.403 in turn referenced Specificatiot 860-72 which called for compliance ,
l with Appendix B.
i
ORGANIZATION: E8ASCO SERVICES INCORPORATED ~
- NEW YORK, NEW YORK REPORT INSPECTION RESULTS: PAGE 4 of 10 h0.: 99900505/88-01 In summary, the inspectors found that whether the venoor's QA program was evaluated against Appendix B or the reference Ebasco specification was immaterial due to their equivalence since the latter also called for compliance with Appendix B.
- 3. Audits of Ebasco by LP&L The inspectors reviewed the file of reports of audits performed by LP&L on the Ebasco New York office.
In 1979, an audit (Report No.
79-1, cated September 13,1979) was performed to assure proper implementation of the Ebasco procedures for the Vendor Evaluation Group. The auditors determined Ebasco's program to be satisfactory with only minor observations noted in the areas of dates, signatures, and other required audit report information. In 1980, an audit (Report No. 80-1, dated September 15-18,1980) was perfonned. During this inspection, no deficiencies were noted. In 1981, an audit (Report No. E81-2, dated October 12-15,1981) was performed to review the vendor evaluatiun process. One nonconformance was noted on Ebasco's failure to follow up on an audit performed at the J. C. White Company after it Was evaluated as conditionally satisfactory. Ebasco's response was to follow up on audit findings in a more timely manner for future vendor audits. In 1982, an audit (Report No. E82-1, dated July 19-22, 1982) identified several nonconformances relating to Ebasco's Quality Assurance procedure QA.P.9 and procedural require-ments for auditor training and the certification of lead auditors.
In 1983, an audit (Report No. E83-1, dated February 28,1983) addressed the topic of vendor audits. In the area of procurement document control, the auditors noted that Ebasco placed vendors on the AVL prior to the resolution of audit findings. The classification of conditionally satisfactory was being used without restriction with regard to placement of vendors on the AVL. In the areas of audits, the audit team noted satisfactory performance with several exceptions.
One observation was noted which identified a lack of assessing vendors for 10 CFR Part 21 compliance on Ebasco audit checklists. In 1983, an audit (Report No. E83-2, dated September 13-16,1983) identified problems with nine vendors performing safety-related work In addition, 10and not scheduled being audited within the last three years.
internal audits were not performed nor scheduled. Other areas of concern related to overall audit report practice not being accomplished in accordance with Ebasco procedures, and placing of purchase orders with vendors prior to verification of corrective action for open audit findings. It was noted that in all instances subsequent audit reports addressed the resolution.by Ebasco of previously identified deficiencies.
ORGANIZATION: EBASCO SERVICES INCORPORATED .
INSPECTION RESULTS: PAGE 5 of 10 NO.: 99900505/88-01 In summary, the inspectors determined that the LP&L audits adequately reviewed selected portions of Ebasco's QA program, as related to vendor evaluations, and that deficiencies observed were properly addressed by Ebasco under their corrective action program.
- 4. Auditur Qualifications The alleger claimed that, in several instances in which vendors were resaluated by other Ebasco auditors subsequent to an assessment of the vendor being unqualified, auditors who were not qualified were assigned to perform a revaluation.
The inspectors reviewed the Ebasco procedures for determining the qualifications of auditors and lead auditors and found it to be in coa.pliance with Regulatory Guide 1.146 and ANSI /ASME N45.2.23-1978.
1he inspectors also reviewed the qualification files for each of the auditors and lead auditors involved with the evaluations of the vendors of concern and found that all personnel were properly qualified for the evaluations perfonned. Personnel files reviewco included those for Messrs. Afram, Bullen, Hartnett, Hymes, Marek, Missailides, Panchal, Ryan, and Shusterman.
In sumary, the inspectors found evidence that all Ebasco personnel who performed vendor evaluations for the vendors of concern were qualified.
- 5. Automatic Switch Company It is alleged that, subsequent to the performance of a vendor eval-uation of ASCO that resulted in the vendor being ceclared unoualified to provide solenoid valves due to a lack of an Appendix B QA program, other unqualified personnel were sent to ASCO to review the vendor's corrective action under duress from project management who wanted to place an order. The latter review resulted in acceptance of the vendor's program corrections and placement of the vendor on the AVL.
The inspectors reviewed VE File 669 and determined that ASCO was initially evaluated and assessed as unsetitfactory on February 18, 1962. Following a request by the vendor for the specifics of the audit results, the programatic deficiencies were transmitted by Ebasco on April 14, 1982.
Based on the ASCO response on May 13, 1982, a vendor re-evaluation was performed on June 14, 1982. This audit resulted in a close-out of the remaining corrections and.a declaration of satisfactory.
ORGANIZATION: EBASCO SERVICES INCORPORATED '
NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/88-01 RESULTS: PAGE 6 of 10
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ASCO was then placed on both the corporate AVL and the Waterford-3 List. ASCO was reaudited on June 10, 1983 and found to be condi-tionally satisfactory.
In summary, the inspectors found the process for determining the qualifications of ASCO to be consist with Ebasco procedures and NRC requirements. The Ebasco lead auditor who performed the vendor revaluation was found to be qualified (see Section 4 above).
- 6. ITT Corporation, General Controls Division The alleger indicated that a vendor evalustion was performed at ITT/GCD with the result that the vendor was determined to be unsatisfactory based on the lack of familiarity with Appendix B QA program requirements.
The vendor objected and cited previous rectnt approvals by Johnson Controls and Louisiana Power and Light as proof that their program was acceptable. The alleger believes that a potential legal concern resulted and therefore Ebasco forwarded a detailed list of non-conformances to the vendor for corrective action. The alleger says no response was received, but other personnel perforced another audit which found the venoor to be conditionally satisfactory. The alleger also claims that the licensee was very interested in having this vendor on the AVL sinc <t they wanted to place an order.
The inspectors reviewed VE File 462 which confirmed that ITT/GC0 was audited on April 4,1953 and determined to be unsatisfactory to provide safety-related hydromotor actuators for the Waterford project.
The vendor complained in a letter dated May 25, 1963 citing previous approvals as noted above. By letter dated July 20, 1983 Ebasco sent a list of the QA Program deficiencies to the vendor for corrective action. The vendor responoed by letter dated October 11, 1983 and, based on a reaudit conducted by Ebasco on October 11-12, 1983, the vendor was found to be ccnditionally satisfactory. ITT/GC0 was then placed on the Waterford-3 List as an approved vendor.
In summary, the inspectors found that the evaluation of ITT/GC was performed in an expected f ashion in' that QA prograra deficiencies identified were made known to the vendor who in turn undertook correc-tive action and, based on a reaudit, was found to be conditionally sat-isfactory. The reaudit was performed by a qualified team leader.
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ORGANIZATION: EBASCO SERVICES INCORPORATED ,
REPORT INSPECTION j h0.: 99900505/88-01 RESULTS: PAGE 7 of 10
- 7. James C. White Company The alleger clainis that the J. C. White Company, a supplier of 56fety-related clamps and tube tracks to support instrumentation tubing at Waterford, did not have an adequate QA program for the manufacture of tube tracks in that traceability of materials was not properly controlled. This situation was identified in the 1981 time period and involved the commingling of ASTM A-570 and A-569 sheet and fitting material for comercial grade and safety-related ordsrs.
The inspectors found that the vendor had been evaluated seywal times beginning in 1977 and was found to be 'tisfactory or conditionally satisfactory each tine. However, apparently Ebasco was not always conscientious in assuring the expeditious implementation of corrective action by the vindor as evidenced by an expression of concern from Louisiana Power and Light in a letter to the Ebasco project manager for Waterford; the letter dated August 3,1981 calls for resolution as soon as possible of QA program deficiencies identified at
- d. C. White since as long ago as August 1978. Corrective action was taken as described in letters dated December 4 and 22, 1981 and a reaudit was conoucted also on the latter date with the result that the vendor was evaluated as satisfactory.
Ebasco resolved the question of traceability by identifying the cuspect receipt inspection and isseing a Nonconformar.ce material during(June 10,1981). The NCR called for the review of the Report W3-2749 vendor documentation for compliance to the purchase specification LOU 1564.407A, evaluation of material chemical aad physical properties, and reaudit of the vendor's QA program. The closecut of the NCR indicated that the tube track material acequately met the specification requirements, and appropriate corrective action for the QA program deficiencies was implemented by the vendor.
In summary, due to ine comingling of A-569 ano A-570 material for comercial grade ar.d safety-relating orders in the 1981 timeframe, a question arose regarding the traceability of material used for the tube
- rocks for Waterford. The problem was discovered during receipt inspection, an NCR was written, and resolution of the NCR resulted in a determination that all materials were acceptable.
- 8. Cardinal Industrial P toducts The alleger statts that, despite an initial vendor audit of Cardinal on February 16, 1981 which resulted in a conditionally satisfactory e
- ORGAhlZAT10N: EBASCO SERVICES INCORPORATED .
HEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/88-01 RESULTS: PAGE 8 of 10 evaluation, a reaudit of the vendor on February 2-4, 1982 to determine its qualifications to supply ASME materials, which was not covered in the previous audit, resulted in an unsatisfactory evaluation. In the mea,itime, Ebasco had placed a purchase order with the vendor for ASME fasteners based on the initial evaluation. The alleger claims that this resulted in a situation in which an unqualified vendor was supplying safety-related items contrary to the requirements of 10 CFR 50 Appendix B.
The inspectors reviewed VE File 764 and confirmed that the vendor audits were perforved with the results as described above. It was also noted tnat there was apparently some confusion in the Ebasco organization regarding whether a vendor evaluation against Appendix B requirements would also serve as an evaluation of Metallic Material Manufacturers and Material Suppliers against the requirements of ASME 111 NCA-3800. The oroer for safety-related fasteners was placed based on the vendor's initial a Mit which resulted in AVL status. However, Ebasco's Vendor Evaluation Group determined that there was a need l
for the second audit to determine conforn.ance to ASME Code require-ments. To respond to the identified deficiencies relative to ASME requirements. Ebasco performed an inspection on August 31-September 2, 1982, of Cardinal documentation records pertinent to the purchase order in question (P.0, WP3-7378) and identified a number of discrepancies regarding material traceability, CMTRs, and material suppliers. A follow up visit to the vendor on October 28-29, 1982 was conducted to further review material traceability and the availability of CMTR data from subvendors and material suppliers. This visit resulted in '
the acceptance of some items without exception, the acceptance of some items by NCRs and the non-acceptance of the remaining items by the 4 issuance of NCRs. In the latter category, four NCRs were written (NCR-587,580,589, and 590) which were ultimately resolved by performing additional testing, and by obtaining the necessary material certifica-tions. The vendor was subsequently removed from the AVL and no further ,
cuoits were performed or orders placed. In addition, the Ebasco proce-dure for performing vendoi' evaluations (QP-P.9) was modified to include l a checklist specifically for determintig compliance with the QA require-ments of A5ME 111 hCA-3800. Personnel performing the reaudits of the vendor and review of documentation for material acceptability were determined to be qualified (See section 4).
In sumary, while a purchase order was issued to Cardinal Industries with some confusion regarding the vendor's r,ualifications to satisfy
' the QA requirements of ASME Ill NCA-3800, Ebasco took the necessary steps to assure that the purchased items met the specifications and Cooe requirements prior to acceptance.
r ORGANIZATION: EBASCO SERVICES INCORPORATED .
NEW YORK, NEW YORK REPORT INSPECTION F.ESULTS: PAGE 9 of 10 NO.: 99900505/88-01
- 9. NAMCO Controls This vendor, located in Jefferson, Ohio, had been evaluated as acceptable and was placed on the AVL. A reaudit conducted in October 1981 resulted in a conditionally satisfactory evaluation. While resolving the deficiencies in the QA program during the mid-1982 period, the vendor relocated its manuf acturing f acility to Newton, North Carolina. The alleger claims that, since the facility was in the process of moving, it was not possible to complete the vendor evaluation (i.e., the adequacy of implementation of the QA program could not be evaluated). However, in response to complaints from the Ebasco project mana er's office to expedite the vendor evaluation to permit an order for imit switches to be placed, another auditor was ser.t to the vencor's new facility to review the QA program also with no input on implementation. On this basis, the vendor was detemined to be conditionally satisfactory and the order was placed.
The tiispectors reviewed Ebasco's audit file for NAMC0 and verified the conditionally satisfactory audit findings of the October,1981 audit as documented in February,1982. In May 1982 Ebasco responsec to NAMCO indicattr.g that the responses to the deficiencies were unsatisfactory and a new reply date, June 18, 1962, was established.
On June 14, 1982 NAMCO notified Ebasco that effective July 1, 1902 it was relocating its manufacturing f acilities to North Carolina.
On September 15-17, 1982, Ebasco perfonted an audit at both the Ohio and North Carolina facilities and evaluated the vendor as conditionally satisfactory. As a result of this audit, NAMCO was placed, for the first time, on the corporate AVL in September 1982. NAMCO responded to the audit findings in October 1982 and was reaudited on April 4 5, 1983 and found to be satisfactory.
In summary, the inspectors detemined that adequate audits were perfumed at the two Vendor locations by qualified auditors prior to placing NAMCO on the AVL. Also, the exchange of correspondence between Ebasco and the venoor was appropriate to resolve the audit findings.
- 10. Persons Contacted Ebasco:
- 4Bert Mazo, Vice President
- 541 Sparacino, Consulting QA Engineer
- sNobil Kcddis, Quality Assurance .
- rRichard L. Hymes, Project QA Engineer 9 Joe F. Marek, Suoervisor, Auditing
ORGANIZATION: EBASCO SERVICES INCORPORATED ~
NEW YORK, NEW YORK PEPORT INSPECTION NO.: 99900505/88-01 RESULTS: PAGE 10 of 10 Persons Contacteo (con't)
- Kenneth Afonso, Project Procurement Supervisor
- Ken Rowland Quality Assurance
- Charles R. Healy. Director Quality Assurance Robert Nespeco Mike Brooks George Afram, Auditor J. Gushue Aucitor Brian Gibson, CA Manager, Auditing Ross Tierno, Personnel NRC:
- Walter P. Haass, Sr. Reactor Engineer, VIB
- Robert L. Pettis, Jr., Reactor Engineer, VIB
- - Attended Entrance Meeting
- - Attended Exit Meeting f
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