ML20197E338

Insp Rept 50-298/86-11 on 860317-21.Violation Noted:Failure to Include QA Requirements in Purchase Orders

ML20197E338
Person / Time
Site:	Cooper
Issue date:	05/01/1986
From:	Jaudon J, Mcneill W, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20197E304	List: ML20197E299 ML20197E327 ML20197E338
References
50-298-86-11, NUDOCS 8605150234
Download: ML20197E338 (8)

See also: IR 05000298/1986011

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/86-11 License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District

P. O. Box 499

Columbus, Nebraska 68601

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS Site, Brownville, Nebraska

Inspection Conducted: March 17-21 86

Inspect s: d 4/ M [

gW.g. McKeill/ Project Engineer, Project Date

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Section A, Reactor Projects Branch

(paragraphs 1, 2, 3, 6, and 7)

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t/. Sk , Project Engineer Project Date

Sheti A, Reactor Projects Branch

paragr phs 1, 2, 4, 5, and 7)

Approved: O

./P. udon, Chief, Project Section A Date

Reac r Projects Branch

Inspection Sumary

Inspection Conducted March 17-21, 1986 (Report 50-298/86-11)

Areas Inspected: Routine, announced inspection of the procurement program,

offsite review comittee, offsite support staff, and actions taken with regard

to previously identified inspection-findings.

8605150234 860507

PDR ADOCK 05000298

G -PDR

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Results: Within the area inspected, one violation was identified (failure to

include QA requirements in purchase orders).

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DETAILS

1. Persons Contacted

NPPD

L. R. Berry, Nuclear Licensing and Safety Engineer

R. D. Champlin, Instrument and Control Engineer

J. Cooper, Environmental Manager

J. R. Hackney, Lead Electrical Engineer

• G. R. Horn, Nuclear Operations Division Manager

A. J. Hubl, Mechanical Engineer

J. S. Larson, Senior Quality Assurance Engineer

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D. L. Lostroh, Mechanical Engineer

• E. M. Mace, Plant Engineering Supervisor

I D. Marsh, Purchasing General Manager

• J. M. Meacham, Technical Manager

M. A. Parr, Instrument and Control Specialist

R. O. Peterson, Senior Staff Engineer

., J. M. Pilant, Technical Staff Manager

D. L. Torcson, Quality Assurance Specialist

G. A. Trevors, Quality Assurance Division Manager

K. C. Walden, Engineering Supervisor

D. A. Whitman, Program Control Manager

R. E. Wilbur, Nuclear Services Division Manager

• V. L. Wolstenholm, Quality Assurance Manager, CNS

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j * Denotes personnel attending exit meeting.

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Actions on Previously Identified Inspection Findings

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2.

(Closed) Open Item (298/8326-01): Procedural Conflicts.

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The documents referenced in NRC Report 50-298/83-26 had been renumbered.

j Procedure No. 1.13, Station Design Changes, had been revised and

redesignated as procedure No. EP-3.4, Revision 3, dated December 26, 1985.

The NRC inspector found that Section IV.A.3 did not appear to'take

exception to 10 CFR 50.59(a). NEP-10 had been redesignated NEDP-10,

Revision 11, dated January 22, 1986. By attachment, NEDP-10' incorporated

procedure EP-3.4 the NRC inspector found that this method of

incorporation of one procedure into another by attachment precludes

editorial differences. This item is closed.

(Closed) Open Item (298/8414-02): Verification that contract revisions

and vendor responses are being reviewed and approved.

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This item was addressed as part of the procurement control activities

inspected in the subsequent section of this report. Effectively this open

item has been reopened as an unresolved item in that section of this

report. The NRC inspector found this contract in question has been

closed. This item is closed.

(Closed) Open Item (298/8414-03): Review of the CBI audit.

The NRC inspector found that the CNS review of CBI Fermi site activities

was not used as the qualification audit of CBI as a wndor.

Gilbert / Commonwealth's audit of February 28-29, 1984, was used by the

licensee to qualify this vendor. The NRC inspector reviewed this audit

(VHF-406-01) checklists and its closed out report. This item is closed.

3. Procurement Program

The objective of this part of the inspection was to ascertain whether the

licensee was implementing a QA program to control procurement activities

that is in conformance with regulatory requirements, licensee commitments,

and industry guides and standards. The NRC inspector reviewed the Updated

Safety Analysis Report (USAR), Quality Assurance Program for Operation

Policy Document, Revision 2, dated April 29, 1985, and the following

procedures:

Rev.

Procedure Title No. Date

QAP-1400 Procurement and Control 11 10/31/83

of Essential Spare Parts,

Equipment, Materials, and

Service

QAI-16 Supplier Approval 10 4/22/85

NEDP-15 Requisitioning 13 1/22/86

In addition, the current " Approved Supplier List" dated February 26, 1986,

and a sample of 19 purchase orders were inspected. The design change

files associated with four of these purchase orders were also reviewed.

The equipment qualification report, vendor quality assurance manuals, and

the General Electric " Instrument Data Sheets" (design basis) associated

with these purchase orders were reviewed as applicable. The safety

classification, quality assurance standards, technical requirements,

quality assurance review and approval of these purchase orders was

verified. The placement of these purchase orders with currently approved

suppliers was also verified.

During this review, it was noted that 2 of 11 essential purchase orders

reviewed had apparent discrepancies. Before the end of the inspection,

the licensee drafted change notices to correct the problems identified.

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Purchase order No. 251173 to Rockbestos for safety-related power cable had

failed to include the exclusion of the Rockbestos' San Francisco warehouse

that was in a note in the " Approved Supplier Li t" dated February 26,

1986, for that supplier. Purchase Order No. 251900 to Kerotest for

equipment qualified safety-related valves failed to include the quality

standards (e.g., Appendix B, 10 CFR Part 21 and others identified in the

" Approved Suppliers List") for a Kerotest subvendor, Namco, (electric

switches), who was identified in the purchase order. Also the same

purchase order identified the Namco components by two different part

numbers, EA-180 (equipment qualified) and EA-170 (not equipment

qualified). This was identified as an apparent violation to have quality

standards properly included in purchased orders (298/8611-01).

One observation of the NRC inspector was that procedures at the general

office did not require that engineering check or verify the safety

classification of components in the " Engineering Data File" generated at

the CNS site. No misclassifications were found in sample of purchase

orders reviewed; however, it was noted that the possibility does exist for

such to occur.

A number of safety-related activities (e.g., venturi flow elements, fuel

channels and thermocouples) were being procured as contracts rather than

by purchase orders. Also, service agreements as opposed to purchase

orders were used for safety-related activities (e.g., inservice

inspection). One contract, No. 84-40 was reviewed. The inclusion of

10 CFR Part 50, Appendix B, 10 CFR Part 21, and technical requirements was

verified by the NRC inspector. In regard to the quality assurance review

and approval of the contracts, the NRC inspector established that it

appeared that the official record copy of this contract did not have the

documentation of the quality assurance review and approval of the three

amendments to this contract. Also, the official record copy did not

appear to have the third amendment in it. The licensee will be reviewing

contracts and service agreements based on these observations. The

inspection of contracts and service agreements is an unresolved item

(298/8511-02).

4. Offiste Review Committee

The purpose of this inspection was to determine if the functions of

offsite review were being performed in accordance with the Technical

Specifications. The offsite review committee was referred to as the Safety

Review and Audit Board (SRAB). The NRC inspectors reviewed the USAR,

Technical Specifications, Quality Assurance Program for Operation Policy

Document, Revision 2, dated April 29, 1985, and the Safety Review and

Audit Board Instructions and Guidelines, Revision 1, dated March 11, 1986.

In addition, the following documents were reviewed:

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Document Title Date

QAP-2100 Document Control Audit

No. G84-07 Third Follow-up

QAP-1799 Design Control Audit

, No. GR4-04 Follow-up

QAP-900 Environmental Follow-up

Audit 85-19

MDC 84-265 Chemical Waste Sample Tank / January 8, 1985

Waste Collector Tank Cross

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DC 85-57 June 25, 1985

LER 85-57 January 2, 1986

LER 85-21 January 2, 1986

STP 85-21 January 14, 1986

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SP 86-001 January 9, 1986

SRAB Audit Schedule for 1986 December 24, 1985

The following SRAB Minutes were reviewed:

Meeting Meeting

Number Date Number Date

104 February 28, 1986 103 January 10, 1986

102 November 22, 1985 101 October 11, 1985

100 September 13, 1985 99 August 1-2, 1985

i 98 July 12, 1985 97 June 14, 1985

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96 May 17, 1985 95 April 19, 1985

94 March 8, 1985

The NRC inspector reviewed the SRAB meeting minutes and the documents that

the SRAB reviewed as specified above. Discussions were also held with the

SRAB administrator and some menbers. The instructions and guidelines that

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prescribe SRAB' activities appeared to implement the Technical Specification

requirements. The NRC inspector noted that while the guidelines allowed

for the use of an outside consultant as a voting member of SRAB, none had

l been used in that capacity.

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The SRAB instructions and guidelines assigned members by name, and also

designated a Chairman and Vice Chairman by name. These assignments were

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in accordance with the Technical Specifications. The SRAB instructions

) and guidelines also designated a member as the Alternate Chairman.

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However, while the duties of the Chairman and Vice Chairman were specified

in the SRAB instructions and guidelines, no specific duties were described

for the Alternate Chairman. The position of Alternate Chairman was also

not described in the Technical Specifications. The licensee stated that

the Alternate Chairman was a new designation and that the member had not

performed any functions that could be associated with the title of

Alternate Chairman. The NRC inspector cautioned the licensee to ensure

that the position of Alternate Chairman is recognized by the Technical

Specifications and that the duties of the Alternate Chairman are

documented prior to the Alternate Chairman functioning as the title would

suggest. This was not considered a violation since the Alternate Chairman

had performed only as a regular member of SRAB.

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The SRAB did not meet during this inspection. Items on the meeting

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agendas were reviewed by members prior to the meetings and questions or

, comments were documented and addressed at the meetings. Members were

! required by the SRAB instructions and guidelines to obtain at least

20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of training each year, and visit the site at least 3 times each

year. The SRAB minutes documented any training and site visits completed

since the previous meeting. From the documents that the NRC inspector

reviewed and from discussions with the licensee, it appeared that SRAB was

effective.

No violations or deviations were noted.

5. Offsite Support Staff

The purpose of this inspection was to ascertain whether the offsite

support staff functions were performed by qualified personnel in

accordance with the licensee approved administrative controls. The NRC

inspector interviewed selected personnel, reviewed organization charts,

and reviewed personnel records to verify individual qualifications. These '

controls or procedures addressed design, quality assurance, procurement

, and their interfaces between onsite and offsite. In regard to offsite

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support staff, there appeared to be sufficient number of qualified personnel

to perform assigned functions. Personnel interviewed appeared to be aware

of their assigned functions and responsibilities. Administrative controls I

were found in place which describe the responsibilities, authorities, and I

lines of communication for the offsite support staff.

No violations or deviations were noted.

, 6. Unresolved Items

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Unresolved items are matters about which more information is required in i

order to ascertain whether or not the items are acceptable, violations, or l

deviations. The following unresolved item was discussed in this report: '

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Paragraph Item Subject

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2 8611-02 Inspection of contracts and service

agreements

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7. Exit Meeting

5 The NRC inspectors conducted an exit meeting on March 21, 1986, with the

i licensee personnel denoted in paragraph 1. Both NRC resident inspectors

l also attended. At this meeting, the scope and findings of the inspection

t were summarized.

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