ML20205A089
| ML20205A089 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 05/16/1986 |
| From: | Engelhardt J, Huth T, Lagergren W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 0004T, 4T, NUDOCS 8703270381 | |
| Download: ML20205A089 (4) | |
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. TENNESSEE VALLEY. AUTHORITY cm SEQUOYAH NUCLEAR PLANI GENERIC CONCERN TASK FORCE GCTF i'
IN-86-011-003 '
Employee Concern Number:
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Supplier's Subcontractors I
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Date of
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- Investigation: May 9, 1986 I ? "TV
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, } J. E. Engelhardt fff
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Dackground
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An_ investigation was conducted at Seguoyah to-determine the validity of an expressed concern as received by Quality Technology Company-(QIC)/ Employee Response Team (ERT) for Watts Bar Nuclear PJ ant (WBN)'.,
The concern was determined to be generic for Seguoyah.by the Watts Bar Concern Response Task Force. The concern of, record, as summarized on the Employee Concern. Assignment Request Form from,QIC and identified as IN-86-011-003,. stated:
TVA does not require material suppliers to involve QA requirements on sub-tier suppliers.
The_EEI.follovup group was contacted to receive further information on the concern. An example was given by the concerned individual to ERT and is stated as follows:
Prior to 1982, TVA Class A bolting material was purchased from Dravo Company. Dravo subcontracted with Texas Bolt Company for this material. The certified mill test-report received from Texas Bolt Company did not indicate that the material was ASME Class'I.
gs No further information was requested from the ERT followup group.
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II.
Scope i
A.
The scope of this investigation was determined from this concern to A
be two specific issues:
1.
Does TVA require material suppliers to have sub-tier suppliers meet the QA requirements for procurement?
2.
Did Dravo supply bolting material for Seguoyah?
I' B.
To accomplish the investigation, Nuclear Quality' Assurance Manual
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(NQAM) requirements were reviewed and the Procurement Quality Assurance Branch, Supplier Evaluation Group (PQAB SEG) was
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contacted.
III. Summary of Findings A.
HQAM, Part III, Section 2.1, " Procurement of Materials, Components, Spare Parts, and Services," list the requirements for procurement l
of QA material. This NQAM incorporates the following requirements:
5 1.
ANSI 45.2.13, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" d
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' Control of Procurement of Items and Services for' Nuclear: Power Plants"
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~ASME,Section III,: article NCA-3800, "Hetallic !!aterial Manufacturer's and.Haterial Supplier's-Quality System Program" 4.
Other applicable standards
.These standards require that sub-tier' suppliers also meet t e same h
QA requirementsLas'the supplier.
" Supervisor of Supplier Evaluation Group was contacted about:the B.
implementation of NQAM, Part III, Section 2.1 and Dravo Corporation's compliance with these requirements. 'QA's; Supplier Evaluation Group audits suppliers of.QA materials to TVA's nuclear-Part of this audit. process is to verify that suppliers i
liers plants.
, maintain a QA program that will assure.that any sub-t er suppDravo Corporati also meet these requirements'.-
certificate which certifies that it meets the QA requirements for.
. Texas Bolt
,._ supplying ASME code material for nuclear plants.
It was
= Company was a sub-tier supplier.of Dravo Corporation. a problems were found..Both Dravo Corporation and Texas Bolt Company ifb.
are on TVA's " Acceptable Suppliers List" for supplying ASME code material. ; Dravo Corporation only hadla contract to supply material ki t.4 #i-C to WBN.
.. Conclusions and. Recommendations IV.
A.
Conclusions
-The-employee concern was found not to be valid fcr thc-folicwing-reasons :
NQAM, Part III, Section 2.1 does require sub-tier suppliers to abet the-same re,quirements as the contract supplier 1:hich is 1.
verified by PQAB SEG.
Dravo Corporation and Texas Bolt' Company meet the. requirements 2.
for supplying ASME code material.
Dravo Corporation did not have a contract to supply material 3.
fer Seguoyah Nuclear Plant.
l B.
Recommendations None
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Page 2 of 3
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References:
ANSI N45.2.13-1976, " Quality Assurance Requirernents for control of Procurement of Items and Services for Nuclear Power Plant" AS!!E Boller and Pressure Vessel Code,Section III', Articles NCA-3800,*
"Hetallie Material Manufacturer's and Haterial Supplier's Quality System Program "'1983 NQAM, Part III, Section 2.1'" Procurement of Haterials, Component -Spare
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L Parts and Services," dated December 23, 1985 Regulatory _ Guide 1.123, "Q'uality Assurance. Requirements for Control'of Procurement-of Items and Services for Nuclear Plants," Revision 1 July 1977
- Procurement Quality Assurance Branch. Audit 86V-14, da'ted October 17, 1986 t
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- and November-18.--1985, RIMS numbers L19 860117.802 and L19 85111S 800:
.respectively
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. M. d oesiens on.ammerous occasions, and as a.; sult of the Regulatory rf:. w"-
IlG :' c s. h s' r} i Pwrfarseseen lagrevessent Progree (RFIP) at Browns Ferry Nuclear Plant N'.Jwn i,_
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6-j (ETI). E3R2 suport was solicited in the form of a review. The review l @g '.,' -
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ee quality level 1 and II items and s e rvi ce s.
Those services or items saanuf actured by TVA we re reviewed for only BTN.
As a part of the NUC FR reorganization effort to move personnel f rca
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Power Stores task force, NCO procurement activities were transferred
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_m to the alte n. I nte ro rg aniza tiona l cons., uni ca tions and working rela-FJ l
tionships we re stated to have been develcred to attack probicas asd g
streamline operations.
NSRS did not include the evaluation of the
@ d-reorganization within this review, but did evaluate the task force
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findings based upon the findings of this review.
III. BARACEMDrT Suf1ARY 1
During the past several months NSRS has been reviewing the procurement
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procrse of saterial:. and services for TVA's operating nuclear plants.
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The review began on June 11, 1964, and continued until the final closcoot in Chattanoogs on December 5,1984. As a part of the review, I
closeemta were held at the cocpletion of the onsite review at BTX, I
SQII, KCO, and FURCH. Throughout this review, people within NUC FR, I
Fower S to re s, ItRCH, and the Office of Engineericg (OF.) were very Mg
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helpful, cooperative, and in many cases candid. Virtually everyons
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interviewed considered _ procurement to be a _ c:a j e r oroblem, and to a was the "other nuv."
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!I large crtent _tbroblem denetsd with a r=^er c131cated people trying hard to do their job as they saw it, but frustrated betause the system, regulations, QA ll 5
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yyterre_ Perceived tg_.ht working against th g Each group within
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_Ag eizh membt.s rt_y r o M ee s,c r e a t e d_ byJ pc PR.
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tasas, there esers give catsgeries withis wtaich identified deficiencies
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l?nrealistic expectations genarelly,$@'M{ e, 4.{ia. ',... ',.h(7)Ta'ECupen-the. procurement of procure-:.q 3,
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< q ueathe to 1 year would be amore realistic. No __e.ne_ knew b_ow long 9'j:s,fh.
"it would take taj urchase materials but it was,generan y accept'ed
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,-- That _1_a.ch _ of knowledge o f the._ prorm.cment system and asso_ciated
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thht-ue procurement cycle and regulations were viewed at
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@ Taaf.ional levels -as a Am rirwed. a s rcaconocks ' telling the sites why they C6ulIoot
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puy hase sa cee thin g versus _ how to pu rcha s e somethin k and were also designed to purchase something (lcw bid)'the site did not went over what it did went.
As a result, the sites were putting more effort into using the system shortcuts through the overuse i
i of emergency purchases and field purchases rather than learning the system for normal procurements and how to work withi.n it.
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There was no procureeect training _ identified at the site s for
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sonnel were introduced to the rigera of procurement by being handed a copy of the site p ro cu reusent procedure (e.g., SOA 45),
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The procure-ment of items appeared to be vi yed by site personnel as a jo as it it were part of an initiation.
required undesirable
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Euressive and/or Ineffective Review of Purchase Requests and Requisitions Typically 17 yprovsl signatures and initials, some by the same d
people required to sign both the purchase request and purchase i
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site-originated procurement.
requisition, were require
- for a The value added to those Scuments beyond wbst the originator.
quality assurance, and aut. rizing official contributed was, for the most part, minimal.
In a very small number of procurements 4
that were considered more complicated, the NCO provided valuable impet. Considering the timeframe to prepare, approve, and trans-
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"' N stit a procurement requisition f rom the sites to vendors for bids,
" O the sites typically took one to four days, Pt'RCH about three h
D d.sys, and the RCD weeks to months. The value added by the NCO, g
stich was primarily editorial in nature, could not support the costissed time 4 slay by t.he NCO in the procurement cycle; conse-g
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guestly, the resseval et the NCO f ree the review cycle and trans-ist et the af fected 3C0 personnel to the sites was viewed by r33 yi se a posities actioe previded the ICO problems and delays were g
set trasef erred ertth them.
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{ f All m.____ta generated by the sites, both QA and non-QA, were
,}
rnienaed by the site Tield Quality Engineering Group (FQI). For g
'the meet part there was one individual performing that review at
,.., 4 each site. rThose procurements included direct charges, IQTs, Il '.'
field purchases, transfers, and Fiaterial Management Syste.m (MAMS) e aveeders.. For example, at IJN duricg May and June 1984 there y
were 1051 procurement actions or about 24 procurements per day
y.
j that required FQE review and approval. The effectiveness of the S
b review on t. hat ntasber of procurements by one individual is ques-tlenable, and the ef f ectiveness of the review of QA procurements could be edartced if t.be review of non-QA procurements by FQE were performed only on a sampling basis.
C.
Imeffective Use of Available Procurement Systems r;3T _/
wR 4
IQT centracts are supposed to be tis >e savers in that once the IQT
=,
has been reviewed and approved, Requests for Delivery (RDs) g {)ateinst the IQT can be issued directly to the vendor without the 9
p j review and approval process required for new procurements.
j EUC F1's procu.rement procedures negated any time savings af forded
- 2.f zg.
~
h by as IQT because they required the review and approval of each
- \\,p g.
ED as if it were a new procurement. There was no mecbacism to 7,.,1
..j,
identify large use itesa, such as steel, as potential candidates a p f r,;*^ P $ '
ferIQTcontract.s.{
Q.
-.vy w. ~..
na'25 is a computerized system to maintain an established supply
- . g.g h
- : P. t;.C of isvratoried stock items throughout Power, and has the poten-
-;,y N 5-;:{.
3 C.
tial of being a very powerf ul tool. The maximum inventory level
.KJP 15.h
[ t R. '.~.$;,fgl3 and =hi=as reorder point for some materials were inadequate, and the sites established the practice of boarding itema such as mops y '.g, i..'.7q and plastic bottles to cesspensate. Tbe sites viewed the estab-
' g.,+.. ' N.? g limesed se xissau/ minimum levels as arbitrary acd an effort to
.\\. -I7 f. [1}. y -
rwence stack investories. In actuality the established maximum /
@9#-
d===
levels were seither, and the site problems can be attrib-
, "d
- f 1;.D..T
..'.A[ '..7{;.. ' ( j:Q.
-sted to peer ca==,mication between the site and the Materials e
f ;.-
Services Staff (FTGS), who administered MAMS.
' H; : t.:; y,;,
p, 4 g.} '.e;.7.. ;.c f.
Althsagh fletW b.e4 the espebility of reordering QA items automati-m53 -;~
.J
casily, eers laitisted by power Stores, this capability could not
.c
(
be stilised dse 14 the reorder pregt um not being approved as e OA y.
g,,
aptasB.
As seds, esastherited theagea to MAMS inioruation on y, ',,..,*g, speitifiatises, etc.,
could occur.
The reiore, eiforts were
,.jf. I );.
i 1_, te ass its a Q4 prot ras f o r tWtt. In additioe, tWIS had the asyseglity e( ceseisirs like ereers iroe dif ferent sites fer emu M S asserts 1, Det accerdiog te Pr55 pere eoe1 wea cont aimed
>f GC$er of (Jnr Geetrol Cegsseel (OC) retsitarosts owth that it y
so.
aM S
., i N^u s,
~
f
~ -.
s t
M I i
i
- )
{fU y$i'c p g p. %.y'k.QlQf! M.n :
h B.QN< V i;
6
]
24$5l;gyi?.;:.T.?.
k could met be used. MAHS was also' disadvantaged by set having a
'i -' jeg?i.:gcj;g, f.'- eemplete usage history of laventory items. Investory items C* eld
- e h.
.W i
- he mayylemented by field purchases and direct charge perchasas
-[.q.jpp..
dich newt becomme a part of a ussse history.
u,t g,ie,3r A*,
,c p f, I;
- D.
Artervet lack of Plannig s, a,;..v T {b.'*:. T.>..
E3RR did not specifically look at work planning and its asso-
.j.,
. Pf *. ;-
clated imp.act upon the procurement process during the review. It
..,fM[' f* d,*k.".
was covereil in an NSRS review of outage controls (see NS15 Report
.;ll N 7,
R-34-27-SQN/BTN).
It was evident, however, from tbs conspicuoua
{,.G y
'Q',..; p; t.
absence of the discuacion of a planning or scheduling phase
-'g j'i k!. G: '.
during interviews that whatever work planning was occurring, it
{
{ *1' 7 } J ' ~ '
had little positive effect upon procurement.
That obs e rva tion 8
[ *
,'Q;, ' -
was supported by the identified fact that engineers at the plants JA'.-
were scheduling modifications without having the needed material
,..(,
'i onsite, with unrealistic expectations on delivery dates, and were
.]I D; ',,,,
using a large number of energency purchases.
Engineers we re d
.C.i" C '
relying upon their ability to find the needed amaterial somevhere within the TVA system when ordered azaterial had not arrived j:.
onsite.
The review did not attempt to determine how many jobs i,y ',
required cancellation or rescheduling due to r.aterial abortages.
'l f:,;f Contributing to the problem of planning work was the f act thstao
-j one int e rv i ewe d really knew bodopni.1 took to procure _ aQte15,,
'y f,Q E,-
....o, y
~lt is understood ~NY~~h$kS that there ii~no one timeframe appli-
[g/,di;pfd
- i; cable to all items procured. Examples were found by and identi-
.l fled to NSRS of procurecenteDQnged _f rem a few days to E cr g:.;.i h
.three years and still wa_itloj.
A reasonable estimate abould be gj.,.
established for rcutane procurements based upon past procure-
.g.,_
ments, be it six clonths or,one year, for use in planning and j
. ld$
schedulina.
}
N.G-l E.
!Ouality Assurance 2 ?'.. ' '
q E
l F.:
The quality requirements for items procured was a portion of this
~
review.
The Operational Quality Assurance tiacual (00AM) was_
j reviewed with regard to procurement std found_Jo _ Dc_Ist,hir
_ cumbersome and _ conflicting in some cases.
The main problems l,
'Tdentifice were tne intermingling of 100% Part 21 requirements j
..a.
with quality apurance requirements and the use of cosamercial g
,rade items as bsste cceponents.
P,,,
g f
[
The quality level I and il designation is used for basic t99Q2-i
~
7 nests a nd__IOCTR21 applicability was determined $r__all wor.ura-g g
men t s wi t h those.AA A vel d e s_ttn a t i o n s_.
In the determination of Fart 21 applicability, Part 21 could be determined not applicable kcasse the item being procured was a coesmercial grase ites.
If commee rcis t grade it-e then the quality retaiteensta P
- s; j it were a coeld be significantly reduced to allow the procurement from se I
L P4 4(
emeFyre,ew weeder med receipt inspectice by sa ineretter met
.t
,selified te Ars! 545.2.6.
The OQAM, Part III, Section 1.1, w tz I, fees for determistas Part 21 etplicability wes esfi-p,'
cteet med woe be iac st oaaed a s tha t if ee itse was 14catifie4 es b censern641 yade m* eetaruinetise wee regatred o! tta e!teet tree. 'j w,-
.i
r g,
~
k,?i fh.NNi.'Ef uG. ' C fi'?
&)gg;.9 1 ',"
y.r :
,/..
Q,:-:
n
- v. s MP the safety function et a C88C co poaast er systan. Maay OA level i
D.I.
I and II: Fa rt 21 N/A, procurseents of commercial grade Stame l
]
N& %p.5 -
required IVA-approved vendors and quality documenta tios.
For
-1 trere seen. All procurements, however, in the QA level I category y;
these trith a QA level II designation, which is almost equally (1'
important f rom a safety standpoint as a QA level I i tem, most
., 7 required no QA documentation.
Procurement with a QA level 8
C/
designation and no QA documentation or manufacturing requirements m"Mb j~h$ -
4 n
results in an implied level of qualaty that just may not t>e 4
there; also, it results in purchased equipment whose quality g p
M characteristics are not known.
p k."/.
tg The use of com>ercial grade items as basic coeponents is allowed 3
y, '
by the FR C.
In using such an item as a basic component TVA "c -
[2l[-
i-assumea the sole responsibility of assuring that tha t ites will l'
l Perform as required when required, including an accident situa-Q' :f..
tion.
Currently TVA has no receipt inspection program for coe-
,Q' mercial grade items that includes testing or soee other mechan 3 ism, such as vendor audit, that can make that sssurance.
,k '
Considering the five basic categories of problems enumerated above amid
.;4' ~
other findings identified elsewhere vitbin this report, a comparisoc
- ,i, c
was made with the findings of the NUC TR Procurement Problems Task Force Report.
Vith regard to the work of the ta.t force and their h..',
findings, NSRS believes it represents a good work effort. Based upon f,9 the findings of this review, NSRS can support many of their recommen-
,3
.,Q dations that are directed toward changing the system, such as:
( Ji Q-
,7 Establish a planning group Improve FURCH/ site c onnuni ca t i o n s
/,'
Eliminate unnecessary procurement cycle steps
)
~]
.g Better utilize autcmated systems NSRS understood that many of tbene recocanenda tions were being igle-s mented, but did not review the extent of the ieplementation. Other task f o rce, rec eecen d a ti on s, bovever, appeared to be direettJLJmr1Id Mitt 6it t 7 system as is or_ developing the ability 7 yJ1sqt_hlame g
within the present system with which NSRS does n'R agree.
g In the details of this report additional problems are identified in y
the areas of spproving vendor services, documentation inadequacies with internal TVA trans f ers, TVA-isbricated equipment, receipt inspec-tion program, and materials with a limited shelf life. As negative as the findings may be, MS p ants to expbasize that the f@n_a re_ag; for the most part peoT e groblems but are_systes problems. People did p ( bsve tha procecures or trajnang to pB o.1s the ta s k krQ-N. N--
.- 1 As ESES sostested soluttoa to the problema found during this review is coetetmed la Attachment 1.
R
=
- l f L
'e
)
l 1
M.
]~
- N Ni p h.w-. %,m..,w 7,3.,
v
@' hk'fh;y;Tf-]'79~. ?':u ".':
i.%
- 3 S-
~V!
'}f-
'a,:c
~ & n.n _.
' f. * ' -
. y': "f* ?.':' ?.
ud.)h
..~
- j
}. t t
k,:' M IY. concLuslaus AND.arcorsaxDATIowa 1 i
..?
A.
R-84-17.!!FS-01 Tbs Procure,ent Systes is Too Cumbermose and Not
.*. gg ;-
W11 Known by the Users
? 5.~
Coselusion-Q,. = g-
?,5j,,'" *,
The biggest probles focad with the procurement system used try NUC Q,*l FR was its wasteful and cumbersome nature.
Procurensents were '
' *?
overloaded with redundant reviews producing little value added in
,h[ ' ['.
. ~
suost cases and causing unnecessary time delays up to months.
1 procurement action with little
- .'M-Virtually anyone could initiate a
. i g'.
or no training. No one was found in the procurement process that knew the process much beyond their sphere of involvement. That resulted in unrealistic expectations being placed upon the system 1 M[
J. -
by the originator with regard to delivery time, and in perpetua-
~
tion by others in the process who did not correct the problems or expectations.
One of the more cuenb e r s ome and redundant review g.
processes occurred within the NCO, and the removal of that review process on October 1, 1984, with the transfer of people to the sites, will help streamline the process provided the Central Office problems were not also transferred to the s i t.c s. lo correct the problems with the system _ drastic introspective manage =ent a na lg sym a c a on ~-requiredlsee sections V.5.1, are M 73 p bf V.D; and V.h).
ip,j T
1
./.
Recorr enda tions h ~R-B4-17-NFS-01A W
G Ibe Irocurement Preblem Task Force r ecommend a ti o n to eliminate f
f all unnecessary steps in the procurecent cycle with the goal of
' k {c, N placing very few, if any, steps between the requisitiener and the d'
- e_g, purchasing agent should be given the highest priority.
i R-84-17-NPS-01B L
A formalized, documented training program covering the entire procurement process should be developed scd required for all
~
j personnel within the procurement cycle from the originator (requisitioner) through the purchasing agent.
t R-84-17-NPS-01C A realtatic timeframe(s) should be established for routine non-i special order procuraments, based upon past experience, to cover the time required f rom procurement origination through receipt of i
the material onsite.
A mechanism should be included in the procurement systes to periodically evaluate and adjust t.ha t j
timeframe as necessary, as well as coesn.nicate the tiJoeframe to involved personnal (planners, procurers, etc.).
II, 1
j 3-A4-17-DTS-01D tia te r ia l avs11 ability and procurcoent timeframes should be in-
~
y c l e.5ed la all metatenaare and modification planalat activities.
(3077.
nia rec omme sda t i es is predicated upoa 1E!sraatita tht E FE is ecev l ep i ng a m a s t esax e a nd **41 f i c a ti et. P l e ar_1et eM
m l
i b
i l
E t m p)?5qm'.a. &
{f;.y..(k..,2y.
9*l"nl.iiQ..1Ti?
~
h.
ethodelleg functice at each site. Also see NSAS RaPert 5-84..
?.4.4*.
SEp/EFR es estase ceatrol.)
1 *; ; _ G'D:.;,..
-d.
R.
R-44-17.NPS-02,1,aek of Approra1 of oneite Vendor Sarvieee at M 7.% u f.,;7pt,..G w
~r y.
@ rb-Q,
Conclusion f.E,,
g 2.
y':.r, The OQAM, Part III, Section 2.1, paragraph 10 requires and iden-
- y ? 3(,.
tifies three acceptable methods for evaluating and accepting the
- -[*
- l;k*Q work performed onsite by vendors.
Contrary to that requirement SQN receiv ed services on three separate occasions and could not
.I f p rovide, after repeated requests, objective evidence that the 2
- a service had been evaluated and accepted in accordance with the OQAM requirement. It is therefore concluded that OQAM, Part III, 9
Section 2.1, paragraph 10 is not being implemented at SQN.
(See section V.B.4.a.)
ai.
2
'4 Reconnendation
.: peogram that satisfies the E
U SQN should d eve lop and implement
-w j
g, requirement and intent of OQAM, Past Ill, Section 2.1, paragraph 10.
y C.
R-84-17-NPS-03, Excessive Review of Requests for Deliveries (RDs) l on IQT Contracts I
Y Conclusion WC PR was reviewing and approving Fis with the same rigor as the IQT ' contract, against which the RDs were written.
That ccnsti-q tuted a redundant effort costing 20 days or more delay in receipt of the cocanodity or service.
(See section V.B.4.b.)
4 Re comen d a t i o n
[
WC PR should streamline its procedure for the review and approv-s al of RDs, with no change of contract involved, to be in line with the requirements of the TVA Procurement Manual.
{
)
_1_nsuf ficient 1)ocu. entation f or Transferred
!f D.
R-84-17-NPS-04, I
Material b
s Conclusion J
3 ID-QAP 4.3 requires the origanal contract to be reviewed by the site receiving the transferred maternal for technical and QA requirements. No objective evidence could be f ound substantiat-l ing compliance. Sites requesting material to l>e transferred to thess by another TVA organization or location did not specifically identify donamenta tion require =cate or require e copy of the ersgamal c oe t r a c *. the material was purchased under. Th et f o rt,
the receiving site had a limited bests for acceptiat meterial l '
dartag the refetPt l as pe c t i on p r o< e s s. The sita assunse4 that all l
l
d c
s l
l 1
(;)*b,'5.$"E.j&i:IE4. *, D q;,,:2..,.' 7 in.;p;. r:
8-
. ;ig.
=
,>.s
{ t *.?
- e.*
4.2..Q i.'n 3m,,.,
applieshle deeveentation had been seat by tan transferring sesse-i ffi.Fp,
.s '
laattee without knowing enactly what the origtsal specificat1*ma
~
i L DIN ~
(technical /%) were. (See secticas V.3.4.c and V.B.5.)
i/!
B - datica
- v...
y, l.R.
FDC PR abould implement the requirements specified in ID-@P 4.3 jl il 4 *.
regarding transferred material. A copy of the origi.nal contract j
[,T abould be in the possession of and used by the receiving site b'.
during receipt inspection, and QC documentation required with tt.e
!t transfer should be specifically identified.
1 1
E.
R-84-17-NPS-05, Cable Assemblies at ETN with Assigned QA Level I Designations Fabricated by TVA f rem QA Level Il Parts witt No I
,'. g.
11e chanis m to Upgrade QA Classification
'=J t ". % -
Conclusion
@h,jhf'$ '
{
Cable assemblies ranufactured by TVA were improperly classified r
Q QA level I items.
The assemblies were manufactured f ree parts with a lesser QA level II designation and no mechanism was found id 4 that was capable of upgrading the QA level designation.
(See i
/
h section V.E.I..d.)
Recoenenda tion 1
RTF should take sbatever steps are necessary to assure that the
,fj cable assecblies, ident.ified in section V.E.4.d, in stock, in use, and fabricated in the future satisfy the technical and QA specifications required.
i b
h,,
T.
R-84-17-NPS-06 EFN Power Stores Receipt inspected Material Not Traiced to Inspect Conclusion Power Stores receipt inspectors are not trained to receive aster-ial with Certificates of Coeplianc. or Certificates of Conform-ante (COC), Certified Mill Test Reports (CMTR), or other similar
[
QC docussectation. On at least two separate occasions BTN Power l
Stores personnel receipt inspected and accepted m.aterial with 4-F OfTRs. One CMTR was for different rasterial than specified in the contract and was not nonconformed.
The other CMTR was for similar amaterial substituted by the vendor but no TVA approval of j
the substitution was found.
Vbile the OQAM, Pa rt III, Section t'
2.2 does not prohibit Power Stores personnel from receipt in-specting material with QC documentation, they should tot be i
allowed to receipt inspect shipments with QC documentation they
' l have met beca trained to interpret. (See sectica V.B.5.)
I Recomunesta t ien h_-
5 lll0 PC e beeld revtse the OQAM to prohibit recetpt ime
. Petties of mu x d-sem.n
,, n. r st. m u,.1 m
.eemarTrw w tte
. a tae c.trect m.cti.
14.___.__-,_______.__
1
=
s r
b jm -
- i..-rg$
- ' Y?RlRV.'Sht.,
l
- p]pf t;
- y p. : 7.7g.f.,~~, a.*.
st,, *.9 M!...I "n '. ',..,,,i, e'
$.T/fv9'M,
2.$
nyy..*. '
- y(p;f{14.'
.}
t.
R-44-17-NFS 07. Material With Limited Shelf Life Not Recrdered Q,,4f.
Jag. Timely Manner 5.@.1'X Coeelusion
+
, U '
The OQAM and DPM system of procedures required the periodic m
_}M,tc. p.
inapection of material with limited shelf life at one half the j
i Jg g s.'* 7 "
abelf life.
Through DPM revisions that OQAM requirement was lW
't.3 "
deleted. Prior to deletion of the requirement, periodic inapec-
,.7f".
tion was being performed (before the shelf life espired) at BTN i
but not at SQN.
BTN required (BT 16.4) reordering shelf life
]
l T4 material with a three-month lead time, but SQN had no require-ment.
Neither ETN nor SQN were reordering saterial with suf fi-
['k' cient lead time to have new material in place before the existing r.aterial shelf life expired.
Considering the latest industry f
3
}.'
philosophy regarding shelf life material, as contained in ANSI /
1 ASME NQA-1-1979, the deletion of inspectica requirementa and O
reordering of items with insufficient lead times to assume an
.."I '
adequate supoly of fresh material is considered ina pprop ria te.
(See sections V.E.6 and V.B.2.)
I R ecocnendat g
[
NUC PR shculd revise the OQAM to establish programs to inspect i
m and reorder shelf life material to anc re an adequate supply of
(
fresh material. Also, the current three-ocnth reorder lead time
.]
.specified in DFM N77A2 should be reevaluated and adjusted as s;
nec es s a ry.
?:
H.
E-84-17-NPS-08, Materials Manapecent Systen (MAMS) Under Utilized i
i r
'.y
- Conclusion i"
j l
The MAMS system was being under utilized in that its capability l
to track invento ry items unase and to reorder inventory items aute.matically was not being used.
Considerable manpower was being expended to perform those functions manually and the MAMS system was not reelving all sources of inventory ite:a usage.
[
One deterrent to a more co.glete utilization of MAMS was the f act l
that its program did not have. ) quality assurance control to
' g prevent unauthorized changes to specifications or other QC infor-nation. Efforts were reported to be underway to prepare a quali-ty control feature f or tWiS which NSRS highly endorses.
(See section V.C.I.)
=
?
Raceaumendstton
,e I
1
- J NDC F1, Power Stores, and the Materials Mana gement Se rvices h
5.ettise should jointly increase e f f orts to utillse the HAME La
- c..
taie anset ef fective sad ef ficient manner possible.
y i
1.
(
r I
__.~
=+
~
m __
1 y
n.
... f., N ~,:, -
u'd y
c l
- .y.,-l....,,3 -
J
- t..m
--y
.yy.. #.;-
- wn, n o.4
- ]!,..' '
. 1.
A-84-l?-NFS-09,10CF1t21 Requirceents Incorrect 1r Linked to NUC FR QA Receirements g
i if-f.,1 -<.
Kfh.. Ckia a-Concluston
' @,,.y?f2$.E.
Reporting of defects and liability requirements ijsposed upon t
r
.Q vendors by 10CTR21 were incorrectly linkad in the OQA?1 to NUC FR
, $* "'..l?,, '
quality levels in that if 10CTR21 was determined not applicable
.q,'.
then saanuf acturing quality and receipt inspection requirements we re automatically reduced.
In addition, the OQAM, Part III, I
Section 2.1. Appendix F, attachment 1, form for determining Part
.l$
21 applicability was incorrect in that if an item was determined i'fl to be corne rcial grade then its affect upon or use within a 3',., ;
Critical System Structure or Component (CSSC) could incorrectly
.2 be ignored.
NUC FR agreed with NSRS that the form should be i '.
corrected. (See section V.C.)
g'..
2..
Re c oenend a t io n
." v hY' '
The OQA*1 and NUC PR procedures should be revised to remove influ-i ecces of 10CFR21 applicability upon the determination of required h
,)
quality levels for items and services, and training in the re-I
., i :
quirements and licitations of 10CFR21 should be provided to all personnel in the procurement cycle.
It is f urther recosamended j that the OQAM, Fart III, Section 2.1, Ap p e n d t z T, a t *.a c bee.n t 1, y
be corrected as acon as possible and separated from the general j OQAM revision so that all questions en the form are anavered whether or cot 10CTR21 is applicable to the ites or service..;.,
J.
E-64-17-NPS-10, Ceccercial Grade Itecs with QA Level I and II Desirnations I
! Conclusica i
1 Ccanercial grade items were being purchased with little or no QA
.e requirements or from vendors ce manufacturern without TVA-S' approved QA p r o g ra nis and riassified es. QA level I or II.
That f
practice was contradictory to the purpose of having QA level 1
~
and II items with considerable QC documentation attesting to its
(
suitability for fulfilling an intended function.
(See sectica f
Y U-)
i 4fg R/(f/
~
g Recoeunendation t/D }
s - ~~~~~, -
)l s
Items purchased with no QA requirement's or liequirements for 4
material certifications (COC, Ctf1R, etc.) and/or f ree vendors or sasofacturers withcut TVA-approved QA programa should not be perchased with a QA level I or 11 designation.
i.
t d, d,fh un$bYfk$$i$':
f N$?Y.N."."Ni T
e
~.
g
~g e
~
r g.!tp #
bg/gfg,GV j
L n-M-17-urs-11, metity Versf acetion for ca nerriel Crede Itese
$f3.::
c,. m.see l
'}_
mQ-CT. -
Gj;.T,.l.ll;.. i '
Q. ;'
The use of cesssercist grade items as basic cooperent.s places the 4
.{
roepessibility for assuring that the itas will inactice as in-
.y tended isoder all conditions solely upon TVA.
The QA program
,j
]
gm.%y.,.
i
}
d' W.'l
.:v;, e. l',.'
within TVA, at the time of this review, was not capable of pro-viding that assurance because it did not include a receipt in-
')
i
..%;. 7..
spection program which included testing of the item or comparable
,I k/./ '-
eechanisms such as an audit of the vendor's QA program for coer-
{g \\.,
g.: #,
eercial grade items. (See sections V.E and V.G.)
p# -
Recommendation 7
{
f J /,i,'.E 5
@c h ;'
4 i
NUC PR should establish a receipt inspection program which in-
'.fif,..
cludes testing or comparable mechanissis, such as audit of ven-t l
' 'f,f /,
f, dor's QA program, verification of certificate of conformance, i
- f.
etc.,
for replacec:ent conssercial grade items that will be dedi-
%g g; cated as basic components or parts thereof, tha t would provide l
M documented assurance that the item will function as intended when L,
j necessary including accident conditions.
~
\\
' ' ' ~
I..
R-24-17-NFS-12, Feceipt Inspection of QA Level I and II Items by s,.
y Conclusion i
Considering the changes recornended by NSR5 in this report with l
regard to the procurement of quality level 1 and II material and
[
! commercial grade items to be dedicated as basic components, the
! ?
l"-
. g,.
division of receipt inspections between FQE and Power Stores, in
- f. '
effect during this review, will be inadequate.
(See sections t
l N.
V.B.5 and V.G.)
Recesamendation
'b,h:. -
' ).I
- All items procured as QA level 1 and 11 and roamercial grade items to be dedicated as basic cowponents abould be receipt
[.,,
lospected by RE or others qualified to ANSI H45.2.6.
j y
T.
DETAII3
~
c,.
7
.o evaluated by review of perticent K2C j
The procurement process was regulations, consensus s tanda rds TVA was cose:itted to. TVA policy 1
l l'-
I J
documents, and various levels of procedures. As part of this evalua-time the precedarsi flow of selected procurements was followed free the eriginator threegh FutCI. EsRS attempted to ideetify all points of originattee for precurements for ope rating nuclear plaats and incloded t.he sits, CE, FCD, vender-surplied itans with ettvites, esid I
^
i
.~
imesrael TYA trueefers between sites and orgentastices. Mo rt thet 184 1
l M
paciaressac rv$sisittees selected at tendes f res 53, 37, 07., et,4 the
.i
(
-d 5:D sers revgeoed.
Of these rettewed, 45 we re selettet f o r fwthest
. stadr se bele; trpeoogstatave ef beete tryes ef prwwetoec:tt it the
1 s
J f
i ges.+
,,a.- y,;..,.-- j.4 %.,i _.-- - z r
-. 9 l.2 *
. p ; __....,' '.}A :','_.*;+.r :.r ?g fgl&.s. : -
' 3,.: :
2.
ff ?.h.ri}tg?p,.g.
g
' ef,.y. ll 1.. :.
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- s. ~.,.c '.,..,.....
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?
[E F;i:[.1.Q.g y;Q l Mr
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Ig hh'N..u. M[%... 'tW '
- i -'<w.b. : ;'~' ;.
l
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m
- ..,p 3 f.-
9..1.c 8
U gn -,. M.1.:.",
M.
w e,,w
. elettrieel, anchestral, sad structural eress.
These p recurennesta j
- 4 Wi',y.j]' ^.. f teclado4 Stame, services, and internal transfers precured as either 1
l(h M y'[..
'. direet charge, ladefinite Quality Ters (!QT) er Material Manasseest i
.;;f' System Ottes) eteck reorders. Of those 45 representative procure-t1 V
amata. 11 tsere followed through the entire review and approval cycle k.,.,
to MEG. Of the 21 procurement actions,12 were classified as emer-
-gencies trith the reshaining 9 being normal procurements.
</ r,.
v6
[,.} "
Daring the course of selecting and following the procureswnt actions ever 90 people at all organizational levels were interviewed with a
regard to their function in the procurement process and problems
?O.
aseeciated with their f unction.
/.t FURCH, in addition to their func-
}
ties within the TVA procurement system, discussions were held on U.S.
4
- c,c Government procurement regulations and their impact upon TVA.
~
A.
Upper-Tier Documents
.j
..U 4
Throughout this review an evaluation was esade which compared the regulatory requirements contained within the Code of Federal Regulations and Regulatory Guides cccusitted to in the TVA Topical Report against TVA implementicg procedures which included the Operational Quality Assurance Manual (0QAM) Division of Nuclear Power Area Program Manus 1s (DPMs) TVA Procurement Manual, Office
.)
of Engineering Engineering Procedures (epa), and applicable plant G(r k'
procedures.
A detailed listing of the procedures reviewed is fg {.
.3' contained in section VII, "Docwnents Reviewed." Except as noted g
i
}
.I' elsewhere,in_this report _TVA's,yrocurement programs,in _the' areas [
- f. f')t
,[
~re+1ewed were in compliance with_ regulatory _ requiremects and,_were af,,
ist emented in accordadw_itt. program proeedurg I~
E.
Plants
[
~
p
'U Ac'tivities at the plants associated with the procurement a n <'.
y 1
nitisaate n eceipt and storage of iter.s and services were revieved.
j
}
Unless othervise specified the findings are applicable to both SQE and ETN.
i s
+
l.
Preparation and Review Cvele for Procurements At the sites procurceent activities were confined primaril to five groups or functional areas of responsibility. Esca is discussed as follows:
I a.
Originator 1-.J Once it was determined that an ites or service was required for operation of the nuclear plaats, some i
individsal had to isitia te the procurement actico and that individual was identified as the origiuter. Aa idestified ia the OQAM aed ieund in ytoeties, the e.riglaster could be say "cessinsat eng inee r, artve r-vleer, er rwaroesible dest nee." The arisia. ster was i
}
[
revyematble for p rete e teg the perchate regmeet med epotif ytag the rees s!! techatest sad q=t1117 rwsstirt-
.i.
s m.,.l:,.**;-
.,g. m.. r--; ::-. A...s :fd n;...y 'A;/ J.~.. -. '. r. :.'. 3, ; '.:l..
h. '. ;<' *', *'*U.C'...:,
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4
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,:; L; y.. q?h;~ &_' _. 3 _,3li(* =
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m: s.,
. -.- QQ. ' ';.i ; '.
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-' ':q
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n.
-f.
n.
s+
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= _ _ -
r.
E. ' '[ p;.
.'s. f..,
h meats associated with the preesroment. Specifically, S
as assigned in the 0QAM, t.be origir.ater shes1d
'I.,:Y.."
.e
- be fes111er with the fanctions of the systme
'g g fdj$.
l the procurement is associated with,
-,g;;
.w.s be f amiliar with the system's importance to
- y.,f * [
f*-
safety, and 3
.s
?,1 Y.k.; 7.',
be familiar with the courpli a n ce, technical, and quality requir'esents of the system.
'j t ' '- <
~....
With regard to the above requirements, and in procure-ments evaluated during this review, all originators e,
C occupied positions where the quellfications to fill those positions satisfy the requirements to procure
!+!
h'. '
i items and se rvice s specified above.
In addition, the
'7 originator was required by the OQA" to specify com-pletely and accurately on the purshase request as s
(
applicable the following; technical description of the procurement
, E *' M. p corponent or system of use
,,; y
'.. W-~
~
M applicable regulatory code
(
'-I I QA levet i
^
f
~ '
design basis N7N ctber cianuf acturing requirements identify required tests, inspections, and jph/
g examinations list documentation requirements
,///@g apecify special handling, packaging, or storage gg<7ggg l
requirements 4
determine the original EN DES procurement QA requireseota m}x, ? c'g,[ Q'(,7/gp evaluate 10CTR21 applicability identify special receipt inspection requirweents A./6My[
specify the data the procurement la waated If the origtaat ar p repa r ed the pe rtkate vet coer-t pistely and occurately as re p re4, se additieul l
review o f the d.e camen t would be mette n a ry,
la prwe-tice, coet t e ry to e s ta b l t s bed p retthrts, tbs w ig tme-
- **==== ame armMis4 to comp ltte the.g w h; toyaset
e o e 0
F e
c'
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4 E.
f M,,.MQ %, -
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emmaple,. the maasfacturer was espected te provide
)
YWi?(
- y
?*!.l ectstately and completely for all itsee above. Ter
,g.
l I P 8 '9 informaties os special headlias, packastas sad starsee l
/
E reqst ressente.
The final QA requirements and Fart 21 b.? l ^ (
applicability were specified by the plant TQE staff and M.i ECO QA Croup, and the final technical re +;uirements were 9'
d specified by the plant specifications engineer and NCO
- {lh'd? "
Q1 Croup.
a I
-cn P
NSRS expected to find a training program for origina-k.Jj',
J; tors in place and functioning.
None was found nor "f. '
required. Vbat NSRS found instead was a description by C
plant supervision of self training. Originators were h.q given a copy of the plant procurement procedure (s) and expected to learn on their own.
As a result NSRS found j.,,
.?
that most routine purchase requests prepared by the
].,
originator were changed at the site by TQE and tiateri-r als personnel. Those changes ranged from significant (wrong QA level or technical specification identified) to editorial.
r.?
f 2/U Wile the originator was required by the OCAM and plant procedures to specify everything requited in all pro-
[
curesients. they were not given the training necessary
',.h,
to accomplish this, m
v.
3.'
b.
Specifiestions Ecrineer E'
l.;.
Once the origir.ator cecpleted the purchase request, it mas sent to the specifications engineer for review of i
the technical specifications and coordination with IQE.,
f other maintenance and engincaring staffe, administra-F tive staff. Fower Stores, and Plant Manager for their input and/or approval.
Basically, the specifications engineer was to assure the purchase request was coo-plete and accurate.
Both BTE and SQN handled this function somewhat differently.
~
d.
At ETN there were positions of specifications engineer for both Operations and Field Services that were staf fed wit.h engineers. For the Field Services Group, F
the specifications engineer assumed the function of the originator and filled out the purchase request.
For I
3 the Operations Group the specifications engineer re-viewed the purchase request as comple ted by the I
originator.
At 50% the specifications engine *r's functica was istfilled by a materials ef ficer free th ttsterials Dmit, wtie.164 set have an enstaaering backgrosad. An attruyt to
- reste, tecbattal specifiestiese woe deu r W4 ht the inactt** Primarily f alfillet nry the l
esteriais offteer wee oos of esMiting pmwomesta.
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E
e 4
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'K hI,N.f,&(WW&fWij.$^ j ' '-
I Fp7,'P.,hid % Y Y Z 9'
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- y Sc.? ( @% -: *;'
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Materials lAsits at both SOf and ETN seers the principel
-l W;h,pd.d;,
f M-poista of costart for technical sad areality assisromes k
A Te : ph "
changes ende la the N E The WCO Quality Engineerias
)
Branch (QE) prepared a form letter to the file with the t
!$[: ;, '
l name of the originator sod TtM perseas coecurring try i
L teley'uose with the NCO changes. It reportedly was (As
)"..G materials of ficer's responsibiltiy to assure tAat input i,
Q *,s '
by the originator or TQ1 was obtained before the 3';fW
- changes were approved.
On procurements reviewed by e
Wl{.
FSR.3, a va ri e ty o f na me s we re li s te d f o r the o ri g ina to r
[?p/ '
concurrence on the QE form letters and most of the time the individual was other than the originator of the u-
,(!
- purchase request.
Some approvals were by technical y.
In personnel and others were by the materials officer.
I all esses the plant TQE engineer approving the purchase
,...,h 5 -
^ff requisition concurred in the NCO changes. The materi-als officers are not technically qualified to approve
. f,_
either technical or QA charges ou their own.
Contra ry i
t r
- I to obtaining the originator's approval for changes, e
i
'(.~.
materials officer concurred in the NCO proposed changes h{
for the originater on four specific irstances (FRs
%2988, 951133, 95'028, 951134).
With regard to TR 7
951134, correspondence was found in the procure **nt C:
file which showed the originator was aware and agreed
((
with the change bett.e the a:aterials officer approval
'9.-
given; however, in the other three cases no similar was d3-M-
correspondence was found.
kith regard to PR 951028, N.
the NCO added a technical requitecent in which the asterials officer concurred and to which the vender 1[,
took exception.
Tt - plant wanted rioc-coated abeet-
[
4;g ;
I
- octal, not oiled.
The NCO added not chemically I
treated. The vendor quoted chemically treated no oil, g,.
and the site materials officer approved the exception.
9-The site materials of ficer should not be concurring in tec.1nical changes.
f Field Quality Engineering c.
The TQE was also required to review quality level I and 11 purchase requests for completeness and accuracy and approve them.
At both SQN and BDi one individual in each TQE group tas assigned that responsibility. ESES o
found that in addition to the procurements of q2ality less! I an: Il materials and s e rvi c es, which this h
~
review centered on, that engineer also reviewed all @
levei 111 and IV procurements as well as eco-QA pre-cu rvuest e. Virtually everything procured by the sites syyroved sad /or reviewed to assure the p rope r was quality level and requirtuests had been placed spee th itse being p r+<ured.
To put p.orepective en the W -
tede e f t ha t effort, ETE pwwer Storse provided a cze-g*,
pilatles of precarements f or fiar and June IM4 ebowing; IC$1 pr*<=coments, b=t did not eMw kee awy ww, goal s tr leve l I er II.
Iket asuber e4 pew <;wwarata
._.,_._.-m
,. ~., - -. ~,
- - ~ _., - _ _ - - _ _ -,, _ _ _ _,
i s-a 3s ke:Qsym}& ;&m?AWW-
- .%:<.v-A hiR 9M m.
y g
c.wh 12 e :
,y,e,7.;g%{g.
3 s e:.
.ij k' ~;5.m,?... :; -
5 4
- f,"E spisuld result la se average of abest 26 per day requir-m c.
r
,,;.,.f., ?.1, W Tgs appenst and/or rnin.
. J!
The TQs rniev et purchaos requests was described La j,f[5(p.
} '
'~p the OQ4H as facluding both tschaical and Q4 require-mesta.
Depending upon the item or service being pro-j l
- ^
cured, TQE described their review as including a coe-perison of the technical and QA requirements with plant l
p@.l'
^
f' drawing s and previous procurements of the same ites.
A.1though NSRS did not physically observe this type of g,.
g.=g/p TQE review in proceas, the mechanics involved in per-M,..
forming it could be time consuming.
Considering the v, C,..
number of purchase requests reviewed, the completeness l
U.'
of each review is of concern. FQE described the number of procurements found with QA levels lower than re-
[
^
, r'..
quired as very few.
The routine review of non-QA
.T.
procurements by TQE is, therefore, considered too time l
h consuming by NSRS for the benefit received, and the time expeuced could be more effectively utilized on QA j
j.
q., :
procurecents.
A periodic review of a samplin-of non-QA purebases should be suffi ient to detect program l '
'(
deficiencies.
I
! U. ;
d.
Plant Furerintendent
'Q Upon ccepletion of the review and approval cycle of the l
[;
purchase request. the purchase request was sent to the plect superintendent for authorization.
c.
Power Stores I
- g. -
[
~
The purchase reques' with all approvals and authoriza-l tion was sent to Power Stores for deterninstion of the L.}
appropriate reethod of obtaining the requested itea(s) 1 j
i and preparation of the associated documentation.
l j
Methods available to Power Stores included direct i
charge procurement using a purchase requisition, re-l quest fer delivery t.nder an existing 1QT contract, field purchase order to purchase items of less than y
$300 free local suppliers, or a transfer requisition (71) used to transfer items free one TVA site to l
snother.
Once the method was selected, Power Stores J
would tras. scribe the approved purchase request writeup l
verbataa ori the apprcpriate form and add on all the 5
perchase request attachments which could include QA and technical specification requirements.
Procuremsat forms prepared by Power Stores were defined as QA decaments in OGW1, Pa rt III, Sectica 4.1, vbersas p.orchase requests were viewvd as worksheets and not QA decamesta.
The offieiai LM denment es.9strwe the 7'
sisaatsre of TQC and the plant esparta' W t.
C==-
(
4 sequeet a r both TTX. end t he plaat superiattedest wm a essist the same rr*<arenrat acties twtet, t
l l
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- - - - - ~,, - - - - -
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he purchase regnest as described to FERS was met tee-u-,, g.. i 4
g*
4w,,}k","
j f'
sidered a @ doomset because it was set alwrys pre-U'
}
The
- -IC'f..
pered la todelible iak and could isde with time.
! $;Yh,(*i,[,
0QAM, Part III, Section 4.1, required @ reeerds to be prepared la ink er typed. la confli6t with that phi-q y^y.y' -
lesephy, NEAS observed attachments to purchase requests j
h' C;.',. [ ',
...,, [,
(e.g., 10CTR21 applicability iorm) that were preysred j
l#
partially la pencil that were classified as 04
- k.,
deciaments.
},
d[.".~..
2.
la addition to signing the procurement form for record
?,.'.N(.
i f
purposes. TQE was required to review for accuracy the dociasents prepared and attachments included by Fower
,g..
Sto re s.
As TQE was the last to see the purchase t g;.
request prior to transcription by Power Stores, their
~
ky' review of the finished product was editorial in nature.
g ch.
TQT., therefore, was required by the OQMt to duplicate its own work in reviewing and approving all QA level I i
- 0..
and II purchases twice.
5h If,' e S
Like TQE, the Plant Manager was required to duplicate bis work in authori=ing both the purchase request and Q,
- f purchase requisition.
With all required signatures obtained, Pever Etores then transmitted the procurement pecuge to Chattanooga for additional review and approval prior to going to
-j
/{?
hc Purchasing.
p j
s
.!p,-
2.
Tunctionicx of Plant Procurement Systen ft I
j i
j 1 Overall, the procurement systen used at the plants contained l
C -
redundancy and was predicated on the concept that additional l
review will promote a better product. As a general rule, a c'
procurement frors the identification of need through trans-mittal of the completed procurement pach ge to Chattanooga g
j g.
contained 10 signatures or initials signifying review and
". R approval of the procurement.
Generally that preparatien 6
process was not considered excessive--taking 4 days for normal and emergency direct charges and 1 day for an emer-l
- sey $D under an IQT contract. More complicated procure-1 f
ssents were seen that required I to 1-1/2 months to prepare.
Of the 10 signatures or initials in the approval process, only 2--the o ri ginator and TQE--were identified se having a
l: ?
emy substantive technical or quality contribution regarding or requirements of the p rocu.rement.
the specificaticas j
Fersemmel interviewed were generally avste of their feettica in the TVA precarement process but generally unawere et the fassetiae med respeesthility of other sections in that pre-t cwes ~ Vtth the possible exception of Power S t o res, know-a ledge of T*4eral p r <wrwoest regilettees was lecting emeeg i
the e La the p rocureerst pr < ess.
f or es.aeple, ese one et i_.__________--_____.___.,_______.___.
y I
~
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b
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., ~ -
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~
. fc, ;.;...
) nr.;wu%
.T7 the p1sete er elsewhere w!Lhas TVA knew how less it mesently b
w'y%q#j ','
took to precere something. They knew it teoh too 1**4 end
- -e.$f:{1
.a. 5? '
eeleen arrived whee needed. The originators weld alleer 90 esys, in establishing a date wsated, f rom the time a per-
$h'M[Jffp.gry,,,/
chsee regeest wee initiated ier restime sonenergesey yer-chases of commoa itses (nuts, bolts, steel, etc.), until m...
Mqb/?OU those itsee trere orpacted onsite. That date was virtually ffI.d.W' [T.
ignored throughout the procurement process. As a result, M,W, -
the purchase requisition rarely arrived at Purchasing with esfficient time remaining, until the date wanted was passed,
'..,Pi f,
[}
to e@vertise for quotations, let alone time to review the and deliver the l$,
quotations, award the contract, manufacture, itee.
Of the requisitions reviewed by N5RS, it typically
. l. e,:
[t y.;3 took 6 months to 1 year to receive material onsite and the sites were only allowing 90 days. With sufficient training y'f in and knowledge of the procurement process, pe r s onr.el within the procurement cycle could establish more realistic
..c :
timeframes in order to receive needed materials.
N.
l '
' E Probably the most frequent complaint about the procurement l
[ i p.
process expressed by the sites was the material was not 5
there when needed.
That cosplaint results in large part i;;;.*A from the unrealistic expectatien ple:ed by the sites upon l
(,{
the procurceent systern.
The site routinely wanta rapid I
I 1*g ;.
resultsg 90 days or less, and the systes can't handle i t..
a
%i 3.
Planning
' ' 24,'.) } ;.
Flanning of work for maintenance and outage modifications was not a formal part of.the review; howeve r, the obtaining i;, ',-
' ' j,' *? -
f of needed materials to perf orm work was reviewed. As iden-
?, ' f.,
tified in section V.B.2 above, ordered material often L
c arrived at the site after it was needed. There was no one i
factor producing that condition but several f actors begin-s.
ning with the originator and including all steps through receipt inspection of the material onsite.
This review j
([
, I focad, however, no evidence ensite that material availsbili-i fartored into the work planning process. For further
]
,[-
ty was informatica on planning see NSRS Report R-84-27-SQN/FJN (GNS
~. y 341220 C52).
j yer essaple, in ECN modifica tion verk, site personnel ex-l plaimed ttsat a complete ECN pscaage was not received f rom IX DES.
Portions of the ECM package would arrive in stages ever some time period. When tta sites had what they be-g%
lieved te be a sufficient amenat of the ECN packmas, work would be echeds1ed sad meterie1e ordered. 143ineses at tbe j
site La charge of the modification work and or4*rint esteri-m' al r-etly stated that the material ordered woeld preably I-e.
arrive before the ECM wrk started.
Coasteering that eetly $4 dsys wee a11emed ier yrenreseeta thet seeetimme l
teet 6 seethe to 1 Te*r to tiet, that esproceed concen une sell femm4ed. Se effort woe f ound, howe cer, to ta-;ee s sm rea ist1c tiseisuse is the eite plsettat resoes.
l
,. -. -, - - ~,. - _ - - - _, -., -,. - - - - - - -. - - - - _
e I.
+
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What resulted, when the mate rial did set arrive, was se 1
W.
1, h.*g'f g. ".' -
ese rcise la resourcefulness by the sita engineers, etich i
g they appeared to be very good at.
The engineers had ta find d.}4 y
J.. ' i the material they needed through borrowing it from seether j
p$i.!'.if:I;'.
a eastaegr onsite, finding it at another site and having it ypfL transferred, or initiating an emergency pu.-chase. Effectivs g
- ~0 /p f f,i
+ itu l' -
as the engineers may be, that effort in resourcefulness is
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time consuming and wastef ul.
With more effective planning a siginificant portion of the time wasted on obtaining materi-
?#E; te
.SN; 1 als could be eliminated.
<[$..!
Special Methods of Obtaining Waterial and Services 4
Much of the erpbasis within this report is generic in nature
- s.,
'.b T1;c sites have I'.3 i end applicable to all types of procurements.
Of numerous metbode available f or obtaining material and ser-
' N."
vices with direct charge contract being the most comeson.
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This review examined net only direct charge contracts but other riethods as well, and this section will focus on tbc 7.l less coexnon cethods and their associated strengths and 4
l-7 weak.nesses, j
I j.'
i a.
Se rvi ce t'c.at -a c t s
- v
- .
a
?..., '
Often the services of consultants or workers with specialized expertise le required.
Like materials receipt inspection, e
bring received at e alte sequires a the receipt of a s e rv ic e at the site also requires an evaluation and acceptance.
Acceptance of a service is s,,,
identified in the OQAM, and three acceptance methods
~.v i
I are listed in Fart III, Secticn 2.1, paragraph 10.0.
On two s epa ra te occasions, SQN obtained the service of Turmanite, Inc.,
to stop leaks ubich could cause a shutdown of the plant. Those services were requested by purchase requisitions 959104 and 955163 vbich speci-
- f...
fied the vendor shall comply with the technical re-O
. }
quir-ments of IQT contract 62P38-925403. On ene occa-f aton a Gulf and Western Service representative was J
requested, under purchase requisition 940060, to per-I l
form work at SQN.
In all three requis itions it was jl l
~
specified that work was to be performed and documented under TVA procedures and QA program. On four separate occasions SQN mechanical maintenance and compliance personnel were asked for the tocumentation contained la the work parkages or ebevbere
'or those t.hree coe-s tracts, which estisfied the acceptance of service requirement o f the OQAM s pe c s f ie,$ a bov e. R323 did met receive any such documentation or an esplanatica of bens the OQAM was estisfied and misst therefore coecle6e that it does eat esist.
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Iedefinite Quantity Ters (107) Centreete
.R;n c o T.-
An IQT contract can be a pcverful tool wbes procuring y kN /.
.,[
h j
i3 J. C.
the same ites or service on a routiae, repetitive basis. When such an item or service is identified, as y
p m
i Q,*.
IQT contract can be prepared following the same prepar-f d
iff.C etion, review, and approval procedures as if it vers a direct charge centract.
IQTs are advertised, sent out t~i for bids, bids reviewed, and contract awarded no dif-
,h I
f e rently than a direct c ha rg e. The difference is, or is supposed to be, that vben items or services are n
.h.
required under the IQT, a request for delivery (RD) is J.f.-
'd prepared and sent to the vendor bypassing the reviev and approval process. That procedure was described as being followed by EN DES, but not by NUC FR.
In each q
of the NUC FR EDs reviewed by NSRS, the RDs went
}.
through the same re.iaw process as the origir.al IQT.
therefore eliminating any savings of sucpower or time gained by having the IQI. Arguments were presented that the IQT was not an actual contract, the RD wa s, and therefore, had to go through the review and approval process to satisfy QA documentation requirements. It was also argued that scce times not everything pur-chased on an D was covered by the original IQT.
7,f.,
..s.
Vith regstd to the first argument, the IQT contract was retained as a QA record as were the RDs.
The RDa specified what was wanted and that the terms and condi-d#
Lions of the specified ICT were applicable.
Each RD was reviewed onsite by FCE and an authorizing of ficial.
t
- ,
- [ -
In NSRS's opinion that should be sufficient to satisfy QA requirements and the RD should be sent directly to the manuiscturer.
Vith regard to the second argument, NSRS views that as a coepletely separate issue.
If an ites or service is to be procured that was not initially contracted for and a change of contract was required, then it should go through the review and approval process as a new procurement.
Tbc.edditional review of s11 RDs by the central office only resulted in additional verbiage added to the RD which was already contained in the IQT. This was con-sidered redundant. unnecessary, and resulting in swed.
Jess time delaya of 20 days or amore. The ellaination of the central of fice review by IrUC F1 should elialaate the pr+blee prealded that in transferries the contral effire positices to the sites the problem was tat tressferred as well. 71st tramaf er wse twt veslutted es a part of this review.
2, le the process of eeslaat Las reecurva**t et th attes, a e r of d a rte t charpe promesseets ter steet vvts
t e
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- ~j' observed at each s.te.
It would appear that an IQT l
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contract would be b<.nsficial for those.
p I
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' J,%$(:
5
- [DO.E A problem with IQTr developsd and vse apparently solved a
It was determined by OGC that RDs during this revie,.
in g
for greater than $10,000 would require advertising as if it were a new pur-g
.:lg.,j;}
the Coesneree Business Daily 3
' 2,[?(?.7.. '
chase. OGC tater determined according to EUC FR pe r-g periodic generic advertisement would be sonnel that a i / D' sufficient to satisfy yederal procurement re gula tions.
l ' p,?.,$.
Transfers j
R
. d * * )..
g~
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y Althotsh the transfer of material within TVA is not of the word, transfers do
. (1, r
procurement in a true sense
?g provide another cosmoonly used mechanism of introducing g
new s;aterials to a site.
As such, tra r.s f e rs were p
y; k
reviewed as if they were procurements from outside 9
h vendora.
a k
l' Many itens have become available for transf er due to the cancelled units and are abipped to all cuclear sites from HTN. Other tr.insfers occur when one operat-f its plant or construction site has unused asterial Lj which can meet an emergency need at another site.
N$
4 NOTE: Transfer of electrical cable was cot pur-sued by the review team at this time.
T>oth ETN and SQN personnel identified documentation prob-W less occuring with cable w*aich resulted in a large number of nonconfocusaces teing writtec.
Basic
' T' as told to NSRS stemmed free lack of f
problems lg.
I coordination between the Office of Engineering 4
7' (Electrical Engineering Branch) and the site and a
documentation accorpanying cable trans-erronecus ferred from HTN.
Most participants were already aware of the problem and appeared to be working co a solution.
The implementation of the solution will be subject to review in Fhase II of the NSRS procurement review.
Torm TVA 4139, " Request for Shipment of Material," is to transfer items between divisions used as the neans (NUC PR and CONST).
The form includes descriptive
[
information of the item, Part 21 applicability, IDE p
signoff, sad other miscellaceous signatures.
ID-QAP 4
l
?
4.3, Tra ns f e r of items," states that the following
~~
steps are to occur in an inte rdiv isional treasfer:
M
+1 (1) Requesting organisation e stablishe s a scurce el y'
available iteme.
(2) Retws t i ng organization preparts returvit for J
'g treaafer.
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(3) Requesting organisation reviews original contract U-[.
for technical and QA requirements.
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n!GW fi (4) Copies of all appropriate records are transferred o e
>~
en the requested item.
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(5) Source organtastien transfers ma te rials to re-ke f!S questing organization.
y
).
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Y No obj ec tive evidence of a technical review occurring Yh@l 0
utilising the original contract could be identified.
Q.
,3 In actuality, the original contract (or copy) was not
.fyj ;.
even requested of the source organisation. Site pro-4 '
j
'Q c cedures and transfer requisitions we re not specific
.y.s.
2 l3 g
enough in stating what documentation was to be sent.
y 1-2 The statement generally found on all transfer requisi-i l
)
.7 tions was, "all applicable documentation" to be in-S, cluded. The employee performing the receipt inspection y,?,
cannot discern if all appropriate documentation has 5
been received if it is not known what the contract i
r l,f ',
applicable required.
The decision as to what was
~~
documentation was the responsibility of Power Stores i
7,j.h' personnel transferring and receiving the ma te rial.
.,.[ '
Quality level material with COCs and CCRs were among
} '
,,{i u..-
the items Fower Stores was allowed but not trained to receipt inspect.
M Sl identified by NSPS involved the signi-Another concern 7'c ficant number of nonconf omances written assinat mater-i 60 ial shipped from cancelled units, usually due to the d,
absence of the original receipt inspection report or a
- /
disagreemer.t between the material shipped and the j
I yyt original receipt inspection report.
In some cases i
esterials have been transferred that are similar to 1,y Z,.
I item requested but technically not the same and use-f, p.21 l
'less to the requesting organizations. Site ceployees exp re s s ed concern in utilizing frTN as a source of j,
sta t e r ial.
basically, they had no assurance that the material received on a transfer would be what was j,,,
[.
originally requested.
Although the HTN shipping pro-cess wasn't reviewed. NSRS identified enough noneco-c.,
formed material to substantiate the concern. Control-4 ling of the HTN warehouse will be transferred from
$ {,
Construction to Power Stores in the future and Fover Stores will establish it as a distribution center, o
l '
W similar to the present Power Stores distributica center located in Chattanooga. The documentation problem on was not limited to HTX.
Ina de-transferred materials quate' documentation singlar to that found free HTN occurred f rom other plant sites transferring snetarials.
4 5.
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TVA Tabritsted Equireent p
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Another mechanism to introduce quality equipment into c..
the plants was for TVA to saanuf acture the part from
^
I5.; *,,r '.;.
e s te.ch material.
This review had planned to include
[ hyC.
.?.'
work performed by the Power Service Shop for the t
i iYd'l[M[*K[,'
I. Dt/
nuclear plante as if the shop were another vendor. This eliminated f rom the scope of the review after the
'i f/ i.-
5 was W **. -
RTM review segment because of time constraints.
g; Before the TVA-fabricated equipment was ressoved from
~
hk ' ^ '
review, operator console cables and control fes-g**
the for the BFN refueling platform and jib crane were
- M G.h i' teens n.i'..i
/
identified to NSRS as betog fabricated by BTW electri-h
?(~[., '
)[ deal maintenance personnel.
Completed control cables
]
ggd festoons were classified as QA level 1 itees and 2.i'.,
Dociamen t a-g istocked within the Power Stores warehouse.
.,i.y'.
h[r, jf[p tion was obtained on the manufacturing process and g
materials used to fabricate those items.
It was detar-IM
. h [v,#
mined that each cable and f estoon was manuf actured f rom p
[
,. s level 11 parts and nothing could be found that
,i h(l 9
9
/
[f showed how the sesembling of QA 1,evel 11 parte produc QA level 1 finished product. Vben identified to P.TN 3
b p'
'3; O dj.
a mana g e me nt, they assured NSRS the matter would be 1
.A corrected.
+
5 Receipt inspection Program
?,f.) *
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The NSRS review of the receipt inspection p ro g ram was M
c.,
., )
k ;.p,
limited to a review of receipt inspection reports and asso-g}'
y ciated documentation.
Actual receipt inspections being
.;C,
g' a
performed were not ob s e rv e d. The review effort consisted of selecting requisitiens at randus from the Power Stores files
. F S
and verifying that all doctments requested in the contract
];
I had been received.
The proper group performing receipt T
inspection as required by the QA lev-l assigned to the ites 4
~
was noted, i.e., Power Stores personnel only or Power Stores g
assisted by TQE inspectors. Selected personnel from Power pr.
U interviewed to verifs their understand-Stores and FQE were 4
fog of receipt inspection procedures.
Those irterviewed f
l appeared knculedgeable of the NUC PT. requirements and site h
I g
procedures.
Y
]L at the nuclear plant sites a
The receipt inspection progrse was directly linked to the quality level assigned to the
, j l I material belag received.
As such, material with higher inspected by }QE inspectors and naterial quality levels was with lower or no quality level was inspected by Power Stores of inspection performed in those groupe clerks. The types I
had varying degrees of dif ficulty associated with them, and inspector training was significantly dif f er-the re f o re, the est betwees TQE and Power Stores perscamel.
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TQE inspectors according to the OQAM perform receipt in*P*c*
l tion of all QA level I, level II substituted itees (items
/
substituted by the vendor as being equivalent to those asked e,
l 3fe[I..;h,j.h 4 for), level II and ICN items to which 10CDt21 applies and (KJ 9 k which are ' shipped f rom the vendor directly to NUC FR.
The
- S/gh[kkfj?1, IV.. ; *O *.
FQs inspectors receive formal training and certification
- U ? -
through the Power Training Center that meets requirements J
established in Regulatory Guide (RG) 1.58 (which endorses
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j
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Certified Power Stores clerks according to the OQA?f perform
- y. ;;,',.
of QA level II non-10CTR21 items QA level III, inspections
,%K QA level IV, and ECN sisterial transferred te NUC FR free p.O CONST regardless of the QA 1. vel.
The Power Stores receit-
[i t,.,'
ing clerka must be certified by the plant QA supervisors.
To become certified, 550 hours0.00637 days <br />0.153 hours <br />9.093915e-4 weeks <br />2.09275e-4 months <br /> of on-the-job r. raining saast 5
J,*., y be completed and an examination passed with a score of 70 3
4';
.? 1 l'.
percent or better.
Recertification was required at inter-not to exceed 18 months.
Power Stores personnel vers vols
~2?'
also delegated (by the Topical Report) the responsibility of 2
inspecting cosamercial Erade itema.
n g
4 The separation of TQE versus Power Stores performing receipt
, i.
inspection occurred at QA I,evel II and was determined by the I'.
applicability of 10CTR21,
R epo r tin g of Defects and Non-compliances " to the item procured.
- /
The docwnentation associated with the QA level 11 items can y ;2 vary from certificate of conformaoce (COC) and certified
)
- L material test reports (Ch 1) to packing slips.
During the j
course of the review, no consistency could be established
.) /.
'M for docu: entation required of QA level II items.
For esample, QA level 11 ite=s with Part 21 applicability could q.
require certificates of ccnformance ptnvided by the manufac-nf' and/or certified materials test reporta.
Centracts l turer for QA level II, Part 21 not applicable, coc11. also have the
. p3,
previous same requirements and/or a packing slip.
c..
- h If a packing slip is the caly documentation requested on a requisition, the inspection is essentially a number check j
T.'f.,
and the "on-the-job" Fower Stores training is acceptable to /
perform the inspection.
However, the appropriateness of Fower Stores personnel perforning document reviews (such as S.
j COCs and CMTRs) that they hav.. not been trained to perform assinat material received is questionsble and of concern to j
NSRS. Examples of Power Stores receipt inspecting OfrRs on QA Acvel II (Part 21 N/A) material were identified at BTN.
/
tiatarial requested was to be either ASTM A336 or A479, type i
'I 316 stainless s te e l. The C?fTR received with the material specified results for ASTM A276, type 316 stainless steel.
f l*
The items weren't nonconformed. The dif ference in meterial beins evolmated by ETN P')A Staf f at the conclusion of l
was the review.
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m... y,. m.m y~.r 'ob ta ined. tj by'; Powe rl.S,to r.O.u.NoI541
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i A basis for ICCIR21 nonapplicability, in the NUC F1t struc-4 k
/ O e ture, was the determination of an ites to be "cosuse rcial
)
l' k
grade."
A cosasercial grade item is considered to be an f
ngl industry manuf actured standard product with suf ficient use i
N
_ O history in non-nuclear applications to justify its use in a 3
I cuclear application. Vben Part 21 was de termined not appli-cable, Power Stores receipt inspected the item.
k 1
L i
ANSI 45.2.6, " Qualifications of Inspection, Examination, and Testing Fersonnel f or Nuclear Power Planta," defines inspec-tion as:
h A phase of quality control which by sv ana of examina-tion, observation, or me.asurement determines the con-formance of saterials, suppiles, parta, ccaronents, appurtcuences, systems, processes or s t ructu rit s to JM predetermined quality require.cate.
I The personnel wbo perform those anspections are required to j
also meet the established s tas.da r is of inspectors as speci-
[
fled ic ANSI 45.2.6.
i If an i t ees has no predetermin d quality, then an inspection as defited above wouldn't arriv. and the Powe r S to re s clerks
'r-pe r f c ruing receipt scspectien wealdn't have to be trained to ANSI 45.2.6 r equi r en:ents.
"J
,e ' f 4,.
h Tne ins p ec t2 r : ard treateent cf a c oerse r c ia l grade item l
,al,; - [
takes on new reaning and t;ecoucs quite important if the item j
/4' M is subsequently used as a b.esic coerponent.
The Code of y',, W'.., ' '
(
Federal Regulations in Tart 21, "Peporting of Defects and Ncocompliance," states that a cocnercial grade ites can be E, #'
B]l' p,
,N.
designated for use as a bas.c c ourpone nt through "dedica-i tien."
The dedication procers in basically TTA accepting l
D-N respen.ibility fcr the quality a nil performance of the dedi-C c a t e d enemme r e t a l i t ern. When TVA.iccepts ttst respensibili-ty, there should be s orse dorm nteil assurance of the quality
(-.
of the ites.
.vu
,' 4.
That assurance could be e s ta bli s t.e d through means a uch a s t.be following:
(1) audit of the supplier (2) testing of the item l
(3) wwrification of certificate of co< formance
[
(4) maint siales recorda donssenting scpplier history i
e 4
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s;, The previously identified concern of Power Stores personnel M4 yf
,K-jg*f.pg, vh 7,3,c Perforatag receipt inspection on materials and related
- dociamentation with einimal training becomes more taperta nt
!.; p g yp, -
s
- , M 9 4'[.P..
.g when realising that commercial grade materials can be dedi-3[N..
- In many cases R ' %p,k[h.r..
'.*.* Yd as bee 1c compocants.
os..
q di.*~
the Power ' Stores clerk is the' only coe who
@, [,** %
has evaluated the quality of an item before use. The impor-f tance of the inspection has gone beyood the basic investery i
'.p g.h E ' 'g.,
of itema received versus items ordered and abould be per-
//
.{.k4.,l.,, $
formed by FQE inspectors who have been trained in the review
.g' i, L' -
of documentation related to procured items.
.b
, v. t
,7ff, However, it also should be emphasized that the FQE inspector 2
receiving the certificate of conformance is basically look-
.g' cjj lr.,
ing for a signature. The review team did not pursue the
- ' D /
validity of COCs but did observe the followingt
' -l' n 3.,
,r (1) No testing is routinely performed oc matarial to verify I,
material properties as s ta ted by the manuf acture rs.
g ij.
(TQE formal training doesn't include testing seethods.)
(2) Not all vendors vbo provide CDCs with coerzercial grade (p
raterial have been audited by TVA.
Therefore, the gr value of the COC would be in question.
C (3) Supplier and product history has not been maintained on )
L'/. '
materials received and used onsite.
The re f ore, no M l,..
documented bases exist to substantiata the acceptabili-NJ.@ $
ty of an ites on that basts.
[
.. t,
'.$ E t-: 4.. '
As a result, for true commerchi srede itees supplied by a
,ij*,;.
vendor witbeut an approved QA program and with no scyporting M
QA documen*stion, the only assuring activity ressining for
- 1. [ '
TVA is testing of the item. No program was identified that M' %.? cf.;., f d.
I tested items upon receipt.
As identified in section V.G d:
I there are no TVA controls over the manuf acturing process or materials for true coamercial grade items that could assure
/ -
i,9y
~,C /-
gI'
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that the materials of construction and operability of an
/
item is acceptable for its intended purpose or its environ-6,.,7 Jy.'.'
ment of cperation.
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NUC PR personnel stated a functional test of equipment was required when repaired or replaced. That test should pro-
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vide suitable evidence that the item functions prepe rly
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however, provide any assurance or demonstrate an ability of
'ht under normal operating conditions.
That test will not,
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If,.
bQ h.}V that itee's functionsbility with respect to time or entiren-j.T D Q.,,
meetal conditions present during.in accident. As such that
- '.r,4
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faectional test is unsuitable for assurina a comme rcial g,Q' grade item maed as a basic ces #osent will fsaction am 4
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retsired daring accidest conditions.
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ly)
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o at least three months prior to their expiration date.
As 1
j stated in section V.B.2, three months may be an inadequate j
lead time.
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Part III, Section 2.2, paragraph 4.3, " Inspections," stated y
(",. -
that " Inspections shall be performed and documented on a
'l
- i.
- periodic basis to ensure the integrity of the itse and its f ;,*
container is being maintained specific inapection y
requirements for equipment and material are delineated in c
DPf1 N82A17." That DPM, which did not cover all items with a p
shelf life, was revised on September 7, 1984 removing the inspection criteria.
i-Consequently, whatever inspection process was intended by the OQAM reference to lower tier document requiruments was lost with the revision of both DPMs.
The Power Storem personnel at SQN and BIN had dif ferent
,)
l
+
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procedures for inspecting and reordering material with a i
shelf life.
Materials were being inspected at SQt near the 4
t, expiration date and then reordered. BD was perf orming am y,
A inspection when material reached about one-half its specia fie1 shelf life but assigned a low priority to the reorder-4
(
ing of those materials.
SQN Power Stores personnel did state that a shelf life itae 3
inspection program would be initiated in the r..a r future.
g-f but no specified date was identified. The prog-so described i
would provide an inspection at six months p r.' o r to the expiration date.
f -
The BW site procedure EF16,4, " Materials, Compocents, and l'
Spare Parts Ecceipt, Handling, Storage, Issuing, Re tu rn to y,
(,
Store F.ooa, and Transfer," was reviewed. ET16.4 referenced g
incorrectly DPM N77A2 for the storage and inspection re-I quirements of shelf life items.
EF16.4, section 4.8, was z., ;
i consistent with DPM N77A2 and required the reorder of shelf life saterial at least three months before the expiration
}.5, date.
T In order to verify complisoce with the P.T16.4 inspection I
i requirenent, three months of compoter printouts (May 1984
.s "s
through July 1984) were reviewed that listed all shelf lif e stock itema due to expire during the month.
A cha ckma r k
(/) had been placed by each item by Power Stores personnel verifring that an inspection had been performed. That type lt of docs-entation did not mest the reqairement of 00AM Part III, Section 2.2, paragraph 4.3, which stated that a form I'
stallar to attachment 4 of that OQAM sectico should be used
.I
,.[
for taspectieaa.
i At 173 five Itame were selected f ree the June 1984 computer listtag to arvaluat e the shelf lif e inspectice process. Of l
these, tue Atmas were jedged by 373 to be La acceptable b-n I
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h ASe condition and their shelf life did not expire for another f
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74;P;y.f. #
year.
Therefore, no reorder was required.
In contrast,
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three of the items were due to expire wit. bin three months i
s f
purchase request had not "p[ y.[,.J.1 i
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and had not been ordered, i.e.,
a
- l. J '
been written.
"i It was emphasized by Power Stores that those small quantity
.('
items were not being reordered until a larger quantity order lQ',,',9 /
could be made.
Certain constraints regarding t.be m i n i==
2/
dollar value of orders were imposed by Fi!RCH and mannf actar-p k
s 3,
.D.*:10 ers.
While the size of an order may be relevant, saata ris t e i ^~
should also be ordered in a timely manner. The consolida-
[
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tion of orders to make quantity orders ** was the responsi-1 bility of fr.SS.
(See V.C.1 f or details.)
in. '
Vben esterial exceeded its specified shelf life, wttich d
I appeared to be a cesroon occurrence, specific app roval by k-1 PORC was required at each site to use the outdated item.
i fiore recent industry philosophy regarding ma te rials with shelf life is contaioed within ANSI /ASME MOA-1-1979, Serple-
{g ment BS-1.
That standard requires that shelf life itema be identified and centro 11ed to preclude the use of iteme
- f 1
cacceding their shelf life.
As such it appears inappropri-d j
ate for WA to remove requirements regarding shelf life Q
inspections, and to ccatinue the practtee of reordering f
material as the shelf life crpires or without sufficiest lead time to assure a supply of fresh material.
C.
Fever Steres c:
1.
EFN and SQN Fower Stores The initial review time in Power Stores was spent gaining an Lnderstanding of the basic :ne cha nic s of site p rocurements (forms
- used, terrinology, coordination required, time 4
I delays, etc.) and reviewing procurement files. Power Stores i*
maintains a file on each procurement, which includes all g
-f available information relating to the specific procurement
- ,.4 (request, requisition, receipt inspection re po rt, etc.).
Thes*. files became a main source of information for the l
1 review team and, with a few minor exceptions, were essen-tially coeplete records. Various personnel were interviewed to ascertain their understanding of the total procurement system and to identify their specific responsibilities and problems within the procurement system. Those inte rviewed
- j appeared conscientious in the performance of their under-j stood responsibilities and demonstrated a willingness to assist the review team in locating documents relating to
- h]
specific procurements.
Areas reviewed included the auto-1g ted reordering of stock ite.s, the utilisation of the tiAn; database, the ab4f life item inspection program, the Power g]
s, Stores receipt inspection proarsa, associated trainina, and
)
handling of records.
(The receipt laspection program and j,
storage of shelf life items were previonaly discused La sectices V.R.5 and V.R.6 respectively.)
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ymn h b IU Power Stores personnel were responsible for typing requisi-A M
U tions and coordinating all the required s igna ture s. They also helped locate needed materials within TVA by utilising I.
fy'..
c
?1 -
available information on the MANS system and assisted in h)
.N coordinating tra.nsfers of materials between divisions and Reorders of stock items were also initi-7b d other storerooms.
3 4M;.j','
ated by Power Stores.
The utilization of the HAMS database onsite was controlled i'
- s '
by Power Stores.
Basic information on stock itmos was 3
ih P available through that system which functioned on a Reorder f,
Point / Reorder Quantity (ROP /ROQ) concept.
In principle a
'V-massmum (MAX) inventory level was established for each item j
U:
to support plant needs without eacessive inventory.
A j
' r. '
mintaun level or RCP was also established which allowed l'
N'-
sufficient time to order and receive replacements without
^
~
exhausting the inventory. When the stock level reached the t
order could be placed for t.he ROQ to i
FOP (HIN) amount, an bring the inventory back to the MAX level. The 21 MIS system
+
also contained data se to the date and amm> ant of an itaa
~
withdrawn at tha t time, i. e., a us a g e his to ry.
The development, maintenance, and changes to the MAHS system 4
with inputa from Fower Stores a nd NUC PR a re the responsi-bility of the Materials Management Servlees Sta f f (m).
The MAX-HIN levels have been evaluated by the 10:S3 in an attempt to better utilize stock inventories, either increas-
[
ing or decreasing as ne c e s s a ry.
A basic prebles f aced try site persenr.el was caused when M*.S $ reduced stock levels based on incomplete information.
Procurements through emergency and field purebases on a specific item were not l
l included in the tW15 usage his t o ry and therefore were not included in the evaluation.
Both users of MAMS and ??'SS
~
personnel offered explanations of why and how stock short-l ages of certain stres occurred.
NSR5 decided that ascer-tanning the validity of the explanaticna would not be l
j fruitful, as lower Stores and MMSS were well aware of the
]
ig problem and appeared to be cooperating in establishing s>eaningf ul usage histories to base stock reductions and l
7 increases on.
L'nf ortunately, the originators at SQ1t and MF i
i felt they were being haepered in their work by not having l
basic saterials available when needed. They considered fttSS
,j j
i the problem because MAX levels weren't high enough.
A j
prcbles, resulting from the shortage of materials in stock y
q and the KAX level being too low, was identified at both ETN I
- j and SQN and involved the boarding of materials.
ll In an attmpt to ensure adequ-ste supplies when needed, user
'{
J {r organizatious would " buy out" certain itema as they arrived j
1 in the stockroce, thus forcing t he reorder of that item.
h;l l
Power Stores personnel stated tha t on some specific itmos, j
j om matter what the MAX level was, they could never keep
-(
material la stock.
Those itema v a ried t a an ocpe and clesa-i tag evypties to plastic bottles and electrical ogsipeant.
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- "r * !D b Power Stores is responsible for issuing satarial de s p%;.t.)i [. D requested and not for questioning the usage of material.
'g e y :Iq';'.'u'..,
"f yW7Yt:.G J The hearding of satorials demonstrated the f rustration level 2
7$((.-@k.$ ~
experisaced by maintenance and -oodification personnel and
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their lack - of confidence in the procurement systan. The "j
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boarding problem was discusse 1 with Fower Stores personnel
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i at the central office.
Plans were described for better
- @-p :
F; utilisation of the Power stores Distribution Centa r in W b b. Y '.
Mk' Chattanoogs as a source of heavy use stock itame.
Flana also included the es tablis hment of the ETW warehouse as a
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Power Stores Distribution Center.
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Contained within the MAMS syst em was the capability of fitSS q
i 9
3 I
.k in Chattanooga to monitor stork levels at all Power Stores 5
h Qhg, l. ' i 'r locations and to automatically reo rde r material as the a
[
.W-reorder point was reached. MAMS.also had the capability of
,,M$..f '
s combining orders of like material, but ttiSS personnel stated
.i j
they were prohibited from using that f eature try OGC. The iqC?d,, '
reasoning behind that prohibition was not pursoed.
h? M
- d While the MAMS systesa has an automatic reorder feature, it iip:
..O was not being utilized because the plant TQE was required try the OQA*1 to review and approve all procurements (both @ and
~
W con-QA). Consequently, all inventory reorders were prepared h.g -
by hand and the combination of li ke orde rs by 1 MSS was l
l lM..
performed by hand.
Rationale for not using the asteestic
{
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reorder system w.te that the ftAMS system was not a QA eystem and chsoges to the information within mat 3 (materist spect-
'.7.1;s s. ' -
fications, QA level, etc.) could be made without Qt know-ledge or approval.
Inf orcution was provided R3RS which p
- explained efforts underway to develop a procedure sceeptable to QA which would protect the itV.S system free unauthorized g,
QA changes.
N5ES highly codorses that effort. Upon coe-i 4
pletion of that feature the tWiS system should be usable to j
[f-a Israer extent, thus eliminating the coesiderable manpower
?,"
requirements currently required to manually reorder inven-toried material.
l 1 p,
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2.
Power Stores Distribution Center 3
i;.,
p f.
The review of the distribution center in Chattanooga and the m*
Investment Recovery Program (IRP) warehouse at if7N was f
.f(g.:,.;
limited to discussions with Power Stores personnel.
4 Fower Stores currently has a distribution center werebouse A
La Chattanoogs. At the time of this review over 100 itema j'
'N
- . wore betag stocked there. The basic concept of that center
' ws e to provide a warehouse of inventoried items th.t the a
7-plaats stockrones could draw f ree.
Described plana included assistsialms a 6-month supply of items, thereby allowing the ylmets te redace their inventory and associated storsg*
9 rep a rsments.
In coecept that idea appears feeH:t.ioes tly
.m y
e,mt but erill reteire the ceeperatise o! a11 tvaceemed to
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.* i work within the systes. During this review, Fower stores vse having difficulty maintaining a stock of mops, for h
Yb Q..
whenever a delivery was made to BFN to replenish their k]
inventory, plant personnel would " buy out" the mops and 2* C >
board them. That process created a real shortage withis the Ih.d.j"%
<=
1
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l f
ne distribution center did not have a QA program, but Power 1
/>q i Stores personnel stated that one was being develop *d.
At
', hg
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M*,.I,. 9 the time of this review the only QA material stored at the d
- yA -
As Power a
?'Yh' center consisted of welding rod and dye penetrant.
h h'.
i Stores personnel were not ANSI N45.2.6 trained receipt y
j Q?
inspectors, any quality material received at the center f
I,.p,
- required an FQE inspector to go from SQM to the cestar to f
perform the receipt inapection.
g.
hp-d r.,
W The IRP associated with TVA's e.anceled nuclear plants pro-vided a vast supply of materials to the remaining nuclear p
7" T4
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plants.
Power Stores was in the process of taking control Y.
@?
of the HTN IRP varehouse operation.
It was described as t
1"t containing saterial with an acquisition cost of approzi-
, L.,.
i r, mately 100 million dollars including approximately 33,000
.i25" J '7 valves.
Approximately 40 percent of that material had QA 5
in a QA system and
{ ',' '
documentation sufficient to support use the remaining 60 percent was suitable for non-QA systems or
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fossil plants.
I.1 k e the Cha t ta noo g a distribution cen te r,
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Power Stores described plans to keep the HTM facility as a distribution center for Israe items.
The HTN facility was g* ;
also having QA and preventive maintenance p roredure s 1
aj x;
d 7. p prepared.
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- i
- i D.
Central Office iM.
.l
.9;j The central of fice portion of the procurement review primarily involved the following groups: Nuclear Central Of fice Quality
,'(!,ft;h'j Assurance Branch (NCO QEB), NCO Materials Mana gement Section
,g (MMS), Central Power Stores, and the Materials fianagement Ser-vices Staff of Operations Support.
- 7. %...
N The OQAM (Part III. Section 2.1) was the reference used to define f li',- [
the responsibilities that each of the above groups had in the procurement cycle.
Flowebarts which correspond to the OQAM-1 were found in DPM N72A14. Requisitions
$'.l.
defined responsibilities ff f or QA level I and II (Part 21 appiscable) naterials and services 6
,i.
were reviewed by various groups in the NCO.
Power Stores and
' ig tit 35 basically reviewed requisitioni. f or inventory items. Ieple-i sesstation of these documents was ev.iluated with only a few excep-
- j tiees to compliance identified,
.f. ',
n It sboeld be not4d that s6any of the NCO trocurement respe.asibili-i k
ties med essociated persenael had been transf erred to the plant y
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sites se Octaber 1, 1984, sod the organisation reviewed by N325
- l.
one the see le ytere prior to Octol.er I,1984 As the functions t
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d.d.W6 N:b'p.:hf W@>h'.fE'.k,'Nh* l '" ' a
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and responsibilities rio longer exist at the NCO, sa individual p
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breakdown of each organisation and associated problaes will act l
[.. t,, 'y ' ', g. i '
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. Presented but an overall ausssary is provided.
N
' Procurements of QA level 1 and Il 10CTR Part 21 spplicable
. ; 3,-p 5?' S.' k,n[,I. I 5
materisla and services were circulated for review and aFPreval
(.'2. '
uf% e N
. hW4((,.'2:
[Nk'.g.
. throughout the NCO groups identified above. The only group erith
'4,'.
l procurement package was the NCO @B.
- 'p any visable impact upon a bgJf T.:y.'
Other groups provided signatures of approval or acknowledgement I
or were within the distribution cycle due to the mandates - of
,3 1,7Yjy '
IJ % F,
- 2N organisational cosasunications. The value added to the procure-
.j f.;-y. if N -
ment documents by QEB on the 21 procurements f ollowed f ree the i
E, 2 M,e sites through the NCO was minimal. For the most pa rt QE3 changes t'
}y were editorial rather than substantive (e.g.,
changLna the d
hj Nf' applicable). Technical
'{
rT verbiage specifying 10CTR Part 21 was
} y ).j i..i.,
review of procurements were also being pe r f ormed by QEB.
Both J,s q, T.,
the OQAM and DPH N72A14 specif'rd it was f.
to be performed try the
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NCO technical branches when required. NSRS found that the tech-
.~l
,nical branches who were previously perf orming most of the tsch-ig,i -
longer doing so asd it was being performed t,-
nical reviews were no J
by an SC-2 mechanical engineer in QEB.
The responsibilities of the t015 were essentially clerical. They were to " coordinate central office PJC I11 procurement c-,1ca-p,(.
7',
tions among the nuclear plants, sower Stores, and the ECO."
[
j-'i7 (OQAM Part III, Section 2.1, 2.2.1)
They also performed a review
[
1 of requisitions for " administrative ccrrectness and complete-E 3
$7, ness." (0QA'1, PART III, Section 2.1 paragraph 3.1.2.10)
The
..(,,
review was s itsil a r to others performed by the site and not con-
' L
',y p ;
sidered nece esary by NSRS. Th e t"Jis s e rv e d a s a p a pe r c oo r di na t o r that moved yA icvels 1 and 11 requisitiers between Power Stores, it' n NCO QEB, a n.1 the technical branches.
Files had also been maina 3
()-
tained en specific requisitions, but these files were not evalu-l
('
ated for coepleteness because they were being transf erred to the i
['
plant sites.
The t'MS also interfaced with other procurement j
The IQT tracains of available funda and groups on IQT contracts.
y* '
- [
administration of IQT contrects were functions still performed by l [*,f,f,. ;
the !?'.S af ter the Cetober IcB4 reorgantzation.
Findings regarding len,;tb of time to prepare, review, and approve ~
h-procurements within b11C PR can be sumarized as follows:
s.
it,
- J' l.
Normal direct charge procurements took 4 days to prepare il L,(
and approve at the sites anil 2 ronths to review and approve M
in the NCO.
O.s.,
- " ~
2.
I.me rgency direct cbstge procurce.nts took 4 days to prepare jl, and approve at the sites and 7 days to 1 month (15 days 1.
- .T '
everage) for the NCO to review and approve.
f
.. i.
3.
Ime rg ency Reque s t s for Delivery too k I day to prepers and y
I li
,y-effreve essite and 8 to 14 days f or the WC0 to review and
,,;9 3.L eryreve.
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t
.: s. 4 " ' y.
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a problem knoeing what a piping classification means on a modif t-classify their cation drawing because the plant engineers don't
- S systems the same way as CE.
That problem results in the plant engineer having to coasrunica te with OI for an inte rpre ta tion j
?/p, '.
before material is bought so the appropriate material specifica-l
's yj f L
' tien can be placed upon the iten procured.
' F.,
- identified is f one good practice was c
that Requests f or Delivery on an IQT contract could be issued
(
T -
i'ii.
Regarding CE procurements, f
ik.
directly froe og without going through the laboriosa review and
- Tf I
d.,#
approval process employed by NUC PR.
Another practice, wtLich 9
wili be discussed further in section V.ti, of questionable validi-
]
ty' was identified. Vbere a larse component van assembled from coeweercisi grade parta (parta not requiring an ARSI 545.2 QA
'[d.
- h 11 emironment.
over manuf acturing) and qualif ied to an l,,
h',','
h 0E continues to procure replacement parta as commercial grade and program v
t assumes the cocrponent maintained its if. classificatica.
I
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3 l.h.,
.o t
?A' 4h No areas for improvement specific to OE were identified in the L'M
. Y
\\p O limited areas reviewed.
1
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T.
Purchssing
[
jl in TGCE involved gaining an understandias Tbc review time spent of the laws pertaining to Feder al proc ure=enta, identifyt.as the g.
,(., -
p*.
purchasing agents' (PA) responsibil: Lies and their specific prob-less within the procurement cycle, and t racking specific requisi-
?.
tions through the bid process and award of contract. Specific
/
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internal FG CH procedures were r.o t rev teved or evaluated des to time constraints. The pas appested conscientous and professional I
@/,.,
perf ormance of their responsibilities and demonstrated a a
in the willingnes6 tc help in improving the procurement systes. They R.
censistently expressed concern over the excessive use o f eme r-3 pency purchases and unrealistic "want detes and how these affect credibility with vendors. The TAs also stressed the ceed to
]bestechnically accurate on all specifications found in requist-l l
f tions. In the PA's opinion, too many specification prob 1ces were being identified by vendors and not within the TVA review cycle.
One review ares involved obtaining a generst understanding c f the legal constraints placed on Tederal procurements.
Many were g
identified including low bid and ELO and small business require-ments.
Many of these reqeitements, including their isrpact upon the procuremeat process such as tine delays, were unknown to site technical and NCO personnel. A relatively new constratst, Public 1.a w 98 72 and the associated requiretient that procurements of
$10,00C and over be advertised in the Coernerce Businese Daily a
known by site personnel and pre-prior to the bid process were sented more corsternation than any of the otbers discussed during this review.
That law allows all interested vendors the equal
]
opportunity to bid on an item and delays bid openics up to Ab j
3 defs.
Untertunately, due to the great numbe r o f itene required f
tusiness Daily by all Tederal 8
to be advertased in the Ccenetre l
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4h5 WaNYrinM@n'tB ferpec't thE@ithetitiM t
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delay i,ould be factored into the ordering lead times'because'm*
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other time delay had been f actored in eitbar try the originator or -
anyone else in the procurement process.
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A consistent problem identified try the PAa was the amount of time
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taken in the resolution of problems identified ee a requis itios
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and exceptions taken by vendora wtsen submitting.bida. The FA did "0E C 08"tu.ni c a t e directly with the originator.
In fact, the FA 2
r, typically did not know who tbc originater was.
The signature of
/
i the originator was not on the requisition. Therefore, the FA h.e4 p
to rely on someone elee (possibly from Power Stores or the Materials Unit ecsite er NCO) to coordinat.e resolstice of prok-7 i
M less identified with the requisition a f te r the bida we re f
received.
The agents varied as to the method amed in the j coordination process alttough all were aware of the resultant g
tis >e delay.
e Anether problem idectified by the pas was the tisme delay involved f in getting bids approved by the NCO QA Staff. The " review" per-
[
f o med by NCO QA (when no excepticos to the contract are taken) h j
censisted of stating which of the lev bidders were cc a list of [
i venders with a TVA-ap prove d QA program.
The process of 15.IE'M ll sending the bids for review was extremely cumbersome and time f censuming.
F1.*R Cl! sent the bid t o M.a na g es en t Services, vbo sent (
i it to Materials hausse=ent. sbo sect it tc QA.
Af te r a pp roval ;
the precess was reversec.
If an exceptaco was icvolved, QA would
- t. d the exceptice te tha site and coctdicate apprcval betveta 1
TCI., Materials Unit, and or3ginator as ne ce s s a ry.
f The tisse delay resulting frca the tiesorandums and paperwork generated in statina which of the 1cwest bidders had a TVA-approved progran was considered excessive and unnecessary tvy a
FSRS. In many cases the FA had worked consistectly with a parti-cular cecasodity and was ke wledgeable of tbc approved vendors.
To eliminate time delays and ezress written cosaunication, it wculd appear prudent to establish Fuidelines to allow FAs the 1
I task of selecting the lowest bidder from the approved vendors I
l list.
That respensibility vould be applicable for cases only in vhich no exception was taken by the vendor.
The FURCZ portion of the review occurred a few days prior to the
, y C<tober 1, 1984 trans f e r of NCO procurement responsibility to the H
estes.
The FAs had limited or no informatice. concerning the changes vtilch would affact the procure.ent cycle. Althocab seme 4
2 time is requi r ed in a t rans ition stage to inco rpo r a te chan gt s,
J the revsew temo considered this s ym; t oma ti c o f wtka t appeared to 1
b be limiteJ csommaicatiea occurrist betwees NUC T1 and FWC2.
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/t pi Th9 NRC regulations and TVA procedure recognize t. hat basic compo*
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ents can have varying degrees of quality placed upon them de-
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f[j,e
,. d Pending upon their importance to safety.
The OQAM establishes n
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- four QA levels (level I,
II, III, and IV) to which items or j -
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a.
services for CSSC may be assigned.
Guidelines in assigning 7
levels are listed in paragraph 3.2.5.2 and are identical M tho**
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listed in ANSI N45.2-1971.
These are interpreted by ESRS to
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range from items requiring considerable QA activities to those
- @d requiring little or no QA, i.e., cosamercial grade iteams of stand-
- j
-T-ard design which have proven successful for saany years.
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reviewing the QA levels in OQAti, Part III, Section 2.1, paragraph l
3.2.5.2, it is found that each apply to CSSC with QA level I j/,.fg..
basically applying to, among other things ASME Code material and a
s g
l items procured to a standard unique to the nuclear industry and decreasing in safety importance to QA level IV with so safety-i related function.
..t Reviewing the definitions contained wit hin 10CTE21, 10CT150, ad associated appendices, regulatory guides, and the OQMi, it seas
-l clear that TVA has equated the f ollow1ng terians k
1.
Basic cesrponent.
2 j
2.
Critical
- ees, structures and components (CSSC).
3.
Structures, systems and courponen t s impo rtant to safety.
4 Safety-reinted structures, systems and ccamponents.
Those definitions being equivalent are used throughout the OQA21 in a variety of contents and introduce conflict and confusios, f f A contradiction is introduced in the description of QA levels III e
and IV.
In the OQAM both levels III and IV are described as being for CSSC items, but elsevbere the OQAM specifies that levels III and IV are not for basic componenta.
^
r The use of cosmercial grade items in association with QA levels
- I; I /
presented cecfusion and contradiction.
Ceemercial g ra de items j?".
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paragraph 3.2.5.2 with QA levels 1 through IV.
However, OQAM,
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were allowed to be purchase I by the OQV1, Part III, Section 2.1, s4-Part III, Section 2.1, parapraphs 4.3.1.7 and 4.5, eactuded level
{ h, II as so option f or purchas ang ccamiercial grade items.
In addi-j ym tion the OQAM, Part III, Section 2.1, Arpendix T, paragraph 2.2,
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stated cosmarcial grade items were not basic components.
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Items procured with quality level I and II designations require 4
f.F cresiderable documented quality control unless procured as com-
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sercial grade. A commercial grade quality level I or II procure-4
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mest could be free vendors with an unsp,iroved QA program, require g
no document 4d quality assurance, and receipt inspected by Power Stores persoonal. Although allowed by the OQAtt most but not all precarements of Q4 level I and II commercial grade itees sees by 2
'1 352S were regst red to be-free vendors with 545.2 apy rved
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As the QA requirements are all assentially the same f o r com-Dertial grade items, X8Rs believes there is a f allacy is trying !
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- II.ty,jl,j t* Pigeonhole purchased cosusercial grade itessa into a variety of I
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QA levels. The origin of this fallacy appeared to stem from the
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L application of 10CTR21 to itema procured to either QA level I or 3
T.. <? T II.
TVA, in tbs OQAM, stated that the determination of Part 21 h." '[
. applicability applied only to QA level I and Il procuraments.
t Determination of Part 21 applicability was contained within OQAM, Part III, Section 2.1 Appendix T.
In order for Part 21 to be
- e,;
determined not applicable, the item being purchased estat have ti U been a couraercial grade item, must not have been a complete basic M.
e eponent, or several other criteria. Appendix F, Attachment 1, d;d * #
was a form. " Determination of Part 21 Applicability " wtLich wtnen f'*
completed became a QA document. The first question asked was "is the item 'coasse rcial grade' (yes or nol.
." I f the answe r was yes. Part 21 was not applicable and any remainins questions remained unanswered, such as, could its failure cause a basic component not to perform its required safety function. FUC PR QA Personnel agreed this was a prcblem.
Considering whether or not a coensercia l grade item could affect the ability of a basic coeponent to perform its safety functice was addressed by tbt NRC when Part 21 was develcped.
In its first. publicatien of Fart 21 as a proposed rule on tiarch 3, 1975, the wording was such that fart 21 rculd be considered applicable to off-the-shelf or catalog items.
In respense to inquiries and public meetings, NRC amended Part 21 on October 19, 1973, arid recognized that cocusercial grade items could be purchased without the Part 21 requirement te report defects and tAs associated liabilities for not reporting them.
This recognir.ed that costner-4 -
cial grade items could be purchased for use as a ba s ic ccarponent and Part 21 would become applicable after " dedication" of the part as a basic c orep o n e n t. Based on discussions with TVA Office of the Ge r.e ra l C o un s e l (OCC), this dedication means to put isto use and at that time fart 21 reporting requirencets becomes the i
responsibility of TVA.
Consequently, the NRC has alleved the use 4
l of items with a variety cf QA Icvels including commeercial grade j
as basic components.
However, the use of coessercial grade items l?
with Tart 21 not applicable does not eliminate the need for scene level of quality, rather it shif ts the burden of assuring quality and the contiated ability of that item to perfons its safety function from a joint manufacturer /TVA responsibility to TVA's sole responsibility. That is, if TVA procures a conseercial grade item for use as a basic component, it reust either assure quality ll during the manufacturing or through receipt inspection, testing, i
or other means.
For a true commercia l grade item that is pur-l chased of f the abelf by part number with no documented quality, the only avenue available to TVA to assure quality is through 1;
l receipt inspection and testing.
II lt la 0Q41, Fart III, Section 2.1, Appendia T (2.3.1) the statement
/j ll is mode, " Specific components, systema, and strwetarwa listed oe lj the CISC list a re basic cceposents by deflaition maleen prmred
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't se commercial grade."
There ta lie a the fallsey. A besit coe-u I
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a basic cesponent whetbar or not it is replaced
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poaent remains y
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with a pedigreed ites er cessaarcial grade itse.
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k kY-Part 21 specifies (21.3(a)(4)) that "a casuperetal grade ites is l
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set a part of a basic component until af ter dedication." It does a.
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not state that.a basic component ceases to be a basic composest
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if supplied as a coenercial grads ites. A commercial grade item rjj 8
can be used as a basic component once dedicated, and it can be g'd i
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.y'l used where its failure could cause a basic component not to E')'Y '... '
perform its required safety function. All the Part 21 applica-I.
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bility means for a commercial grade item is if 'IVA finds it
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defective at some point in time TVA must report t.he defect to
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NRC just as the vendor or TVA would have to do if a defect were
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f ound on an ites where TVA imposed Part 21 upon a saanuf acturer.
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In determining Part 21 applicability one criterion for judging j
yJ Part 21 not applicable is by identif ying the ites sa a commercial i
grade item.
Most Part 21 not applicable dete ritinations seen
'k during this review were because the ites was identified sa being j
coernarcial grade. That determination has resulted in what 552S concludes as a misapplication oflh1 kf.in11&ottof_cosee rtial t
as offered in support of t.ha t concinaioat grade.
One ensli5le Eequisition number 951134 from SQN was written to procure sheetmetal for ECH 2768. The metal was to be s6anufactured p
to ASE specifications and required the manuf acturer, i~ D through Appendix E Attachment 8, to have a quality assurance 3.
program that met the requirements of ANSI M45.2-1971.
The
+
Items being procured were classified as ceamercial grade and assigned a QA Icvel 1 Part 21 not applicable.
1 Purchasing that material to an ASTM Standard and requiring an
.y N4$.2 QA program is certainly enore restrictive and prescriptive than purchasing an item to a catalog number. It therefore should I not be classified as comercial grade. Part 21 may still not be p' ',
applicable, but-for different reasons such as it would not I
adversely affect the performance of a safety function.
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It appears that a situation occurred where material was being e
procured not for a basic corponent but for an application that still required QA level I attention. As the Appendia T. Part 21, N
spplicability form first questioneel whether or not it is comuner-i' cial grade, it appeared that personnel completing the form were taking the easy way of determining Part 21 not applicable by calling it commercial grade thereby avoiding the evaluation of otkr significent qualifying f actors.
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It could be argued that it makes no difference if Part 21 is c
decla red not applicable by either calling the ites ctasse rcial
];
grade or by deciding it is not a b a s ic corpooent. The argussent s.
f
- P b reaks deva, howeve r, when, as stated previously, it la recog-
,p sised that th enamof acteria of consercial grade itene rvoires 0,.
ao eTT**'ed 0% Progree or Pt1 receipt imepectisa Wile other a
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neeCSC tiene may require considerable QA with approved pre
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. grams. An essaple of a determined mosbasic coopeoest Furchase
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with coa!!!cting Part 21 deterstantions is as follows:
$k, Requisitten number 343910 free Sqsf was writtan to procure s
k,Luf9'fjd,Y.?,l.'.,.
- reactor coolant pump seal parts. Specific information was o
provided en the Westinghouse pump and the parts were
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required to be manuf actured in accordance wit.h the originsi ll; 4
requirements of the Westinghouse E-Specification 677355.
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- The plant TQE staff originally classified the procuressent as l
QA level II, Part 21 applicable, but NCO revised the pro-g>i J.$
curement to be QA level II, Part 21 not applicable because Mb '.dW they were not en the CSSC list and would not affect the F-safety function of a basic component. Considering that the h.PJ r, specification used for the seals was developed by the mano-
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W,yl,-
facturer (Westinghouse) of the main coolant pump, it could f
l ihhi well be a specification unique to the nuclear indaatry. Aa
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I, such, the procurement should probably have been identified fa>
an a basic component and de s igna ted Part 21 applicable.
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When Vestinghouse supplied the parts they included the Part
%'a 21 applicability.
g:'
-ka 7.1 In other cases the use of a CA level I or 11 f or a coesse rcial F
grade iten may be it, appropriate and isrply a level of quality that
-l 1
is,just not present. For example i
I Requisition number 93:925 from ETN was written to procure a selector switch f or ECN L2115. It was ordered by the mann-y j
7 e/ f acturer part number, it was assigned a QA 1cvel II, and it (h required a packing slip for documentation.
Qf, gas supply house with to unique QA re-it was purchased from a
(,f r
f} quirement or nuclear standards, it is considered by NSR$ to truly p k (#ph \\{
a cetsprcial grade item.
As such the QA level 11 is con-
, be i.
sidered artificially high irplying quality that may not be fac-l CT ftual.
That switch was to be used..in.a..psnel that was qualified, along with that model_nwi,tchj by TVA,.to IE r e qui r emme nt s.
It
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therefore clearly falls into the_ category of commercial grade l
itema dedicated as a besic component.
?-
CE has made a decision regarding comunercial grade IE equipment.
s Basically stated, if a component is assembled with ccessercial f,
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grade itesa (such as a motor control center) and that coeponent i
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is physically tested to IE requirements and is qualified, than tk quellficatica of that component will remain if replacement 4
parts are the same (same stock number) or equal.
Even though ecamercial grade items are allowed to be used sa besic compeeasts, in doing so TVA assunees added responsibilities i?
which it is not edequately fulfilling. Recogsteins, f or==ple, that TVA had qualified, at scoe point in time, a etemmercial grede itme for ese as a basic ceepopeat or a part of a basic coegenorit, TTA rursently has me progree to assure that f uture reglectessats
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and there-
, ill in f act be exactly the same as the one qualified,%1 kl{.M.' w
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If a true conser grese
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His7s purchased by pairiiGm5ir '6ae a manuf acturer or sirFP M
the maanf acturer or supplier is not required to have an approved I
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. QA progree, and TVA only receipt inspects the itas to assure that
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There was no testing or inspection t
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the part number. is correct.
8
- by TVA identified that would assurn that the ites wmald perform
.h.C.[
required or that detrimental changes to the ites occurred er y,.
as did not occur. X1)C PR does perform e functional test of sevly p,;reh.MW,
- q.,
installed equipment which should provide mosse assurance that it
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bdN2 'l will perfora during routine operations. That test, however, will I
f@MDyI, not provide any assurance that the ites will perform as required
%.9,. ji'.p under accident conditions. Tht p4nuf actureu.ci_cc -- w =1 gradq are under no oblijation or authority to_ identify changes.
.]
i Lh'W;fkA itene N,yl y' ',
M RS was informed that dan ~ges gene. ally E s s'ccompanie4 V e
'. j I
j EQ-part number change by the manuf acturer.
That, however, is by j
' 4. :'i.n convention rather than by requirement. Additionally, what would
.W " ! -
constitute a change would probably dif fer from manuf acturer to a
j -
f./,-j r(if:
manufacturer, and a change as subtle as using a dif ferent lubri-f (which could have a very detrimental ef fect under accident
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cent y' '
conditions) would probably not be considered a c.hange by any y[,'f,".
g h, manufacturer.
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b[f a k s0E personnel interviewed stated that some manuf acturers will not e
i l
p '.,, '
o sell c ourne r c a t grade stesa to a nuclear plant.
OE persommet J
7*'
j stated that if certain manufacturern received an order for a j
ecamercial grade pa rt and knew it was to go, e.g., t o SQt, they g
I would automatically provide the QA doementation on the itas.
delay shipment about six months while assembling the donsmesta-l 2
' ion, and would charge ten times the amount they would charge for
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g\\the same item if it were coarsercial grade. OE stated no value
- 1 i
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dw.a s added to the part, it was not manuf actured any dif ferently l
commercial grade ites, and WA already tLad the ites so NO y J than the
{-
a defect were found TVA would receive its 10CD Part 21 gTTI
.a g otificaticn cn the previous or original orders. To avoid what
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ME ccasidered exorbitant pricing, an ordering procedure
=se j
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l devised when ordering par..
' rom certain manufacturers where tas I
Fower Stores Distribution Ces er was the recipient of the coemer*
l ciel grade itra. Specilir in<tructions were provided to PtstCH on f
i
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the Purchase Requisition not to inent e en 10CFR Part 21, 11 quali.
fication, or nuclear plant. At the tirse the Purchase Requisition ff was prepared, a TransIer Requisit ion was prepared for the use of
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the Power Stores Distribution Center when the itess was received.
j a
j commercial grade ites to a QA item and directed shipment to the That Transfer Requisition changed the classification of the g
appropriate nuclest plant.
- 3 procedure had been reviewed and approved by both OGC and 4
1 J
l That lj OQA. Discussions with Division of Quality Assurance Precurement Erslaation Branch, personnel revealed that the manuf acturer in
~
l questico did, according to CQA audits, have different production d][-/I runs and QA requirements for itees going to nuclest plants; f
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o therefore, it appears that some value was added to the ecommercial N
cy gr64e itse for the tacreased fee.
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This entire pestion was set pursued any further as a part of this review.
N8R8 has serious reservations regarding this l
4p
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practice and reserves final judgement until it can be evaluated
. bO@y.8 Datil that time it would be considered prudent on the I
e
@.T. fD farther.
parta of CL and.NUC PR FRA to evaluate this practice on their
~
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%y'((y&!h
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the T& *,'j.*:3t conflicts, confusion, and fallacy described abere,
'j.,1?fG" y N..-
situation has developed where the QA level sys tem is being
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With the m.hD'/ ', '
N'D; further divided within the levels I and II, through the use of In Part 21 applicability, to accommodate comunercial grade items.
. <f.s,' '
doing so an artificisi QA level is implied for a commmercist grade M ?..,'
ites (i.e.'
comunercial grade ites purchased with no QA and
,f<dNE*
assigned a QA level of I or 11), or items appropriately purchased jl~ f e with a QA level and requirements are called commercial grade.
It l
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is considered more appropriate and less subject to errors if the t',
l.
commercial grade items are recognized for what they are, either
{W)',
QA level IV or non-QA, and procurement of QA level I and II commercial grade items should be prohibited. In addition, all QA level I and II itema regardless of the Part 21 aFplicability should be receipt inspected by TQE.
Fu rthe r, the qsality
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requirements associated with an ites adequa tely performing or
[y,. 7, affecting a safety function need to be separated free the Part 21
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coarse rcial grade determination which has nothing to do with
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Nf-quality. Whether the quality assuring activities for en itee's k
.f",
ability to perform a function is jointly shared by the manufac-turer and TVA or solely by TVA, is irrelevant to the required y,.p f.
quality activities.
3
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There is a basic philosophical problem with the QA program for itema purchased as basic components versus items purchased as commercial grade but dedicated as a basic component.
TVA's g
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I for basic coepenents is based upon adding additional ITA quality assurance activities where there is l
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procurement QA program 2
'.4.
f quality assurance to begin with in the escufacturing process and
!bave no quality.where there is no verifiable quality in the j
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sanufacturing process.
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To fulfill its responsibility when using commercial grade itema
]
basic coerponents, TVA will have to decelop some mechaatsa to I
I as qualify replacement commercial grade itema such as a receipt in-f.
s g
that is more stringent than what is l
spectico sad testing prograra currently in place for QA items requiring TQE receipt inspection.
(Tor additional suggestions and information on receipt inspection
/
see section V.B.5.)
With regard to the QA program associated with procureser.t, the OQAM was found cumbersome and sometimes contra dicto ry, 10CTR21
/
was being used incorrectly as a determinant in l
applicability establishing quality levels, and the Appendia T, Attachment 1 was inappropriate and being j form, for 10CTR21 applicability
)
- miessed, in addition, commercial grade itessa were belag gives /
i I
I l
iny11e4 quality by assigning a quality level to thee, and TVA had M,
[..
se methaatse to assare a cosumercial grade itse used se a basit l
componest weeld f usgtion when needed durias actident tsadities.
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L NUC 71 Procurteent Probles Task Forre' I
The review team interviewed two of the three-member NUC F1 Ly
]\\
gain an understanding of the rd l?.a,-'g$ 9t'ft..
,. cr. e. -,
Precurement trehles Task Force to The task force pertelved problems withis the precifrasest systes.
f, report and receamendations were issued subsequently on Augsat 10,(Loo 640310 free Eric Kvaven to Jim Darling f
3,l;...Ut-
'l984 is a report 294). That report was reviewed by NSRS considering all meterial
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P.% ff The major recosumsoda-
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desiallated during the procurement review.
3 tieas identified in the Kanagement Summary of the task force 4
3
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report were tot I
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(1) Establish an adequate planning group at the plant.
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(2) Implement status tracking systems.
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Set goals for turnaround time for each review / approval w
C7cle atep.
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(4) leprove and add adequate resources for expediting efforts.
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f-(5) Inprove coenunication tietween PURCH and the site,
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(6) Eliminate all unnecessary steps in tne procurament cycle j
with the goal of placing very few, it any, steps between the 3
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requisitioner and the purchasing agent.
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,K (7) leprove the inventory stock out probica.
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.lh' i -
(8) Better utilize the automated systems.
(9) Develop improved QA procedures and training.
7
- v....
}
q.fl:
'I' (10) Redefine QA responsibilities for procurceent.
4
.3. -
[{
l.g,lTj; The iollowing observations were made concerning the proposed 4
recommendations:
- l f
f...
(a) ltens 1 through 5 above have a basic emphasis of incorperat-
'f ing more people into the procurement cycle by adding various
,4 expeditors, trackers, and designated contacts for FURCH and The basic premise is to eliminate the delays.
"., C,
OE interface.
j It should be ecphasized though that time delays at the site 4
,'?,y.
could not be substantiated by the review team.
The only e
consistent time delays involved procurements which traveled 1",
through the Central Office. Those time delays stemmed f ree l;
the amount of bandling a requisition received traveling li r*
l-g between the Materials Management Unit, NCO QA, Power Stores, Central Of fice QA review was elimia titSS, and IVRCH. The nated im October with all reviews now performed at each
.{;
l site.
Adding more resources to the cycle to perform the recosumended f unctions will not eliminate a basic inherest l }I l
.N -
problem of too many people already in the procurement cycle.
e 'l t,-
a v.
43 jy N : s..
ri s
]
A 4
,.gl 19 (b) Altbewsk lies 4 recommends the stiaination of all maneces-g~
esty steps is the precurement cycle. the steps are act tesdily identified in the report.
It sPPears that the estessive tracking proposed would be established to follow a
^'J, jQ.; ; s.
. cycle similar to what presently exists. The tracking would f,
k.8:' d,;.' $;[a s
apparently 4 tart.with the procuressat request and be mais-
'M tataed until the ites is received, set aside, and finally
~
used. Some tracking may be appropriate and effective, but
?
sr the emphasis appears to be to find the people who are not a
.A "i Performing their job properly.
Instead of developing a
.~
j N
method to track all the reviews, more emphasis is needed in j
NN simplifying the present system, i.e.,
identifying the 2.6 :
reviews not needed and better utilization or elimination of s
G"..
resource people presently available within the system.
l1
' C
. t jd ij./.i (c) Fecessary action on iten 7 was observed during the review.
W r.2t1 To alleviate the stock out problem, more emphasis was being pieced on having accurat.e usage history available. fttES and D[/ : '.
E ; ):
Power Stores were coordinatins; that effort. An additional
V Task Force report recommendation to alleviate the stock oest problem was the increased ussge of IQT contracts.
E323 I
c ob s e rve d, under the current NUC PR system, no benefit in g *;.
using IQTs to reduce time delays due to the RD os sa IQT being treated as a new c o n t r.s c t,
i.e.,
going through the same review cycle every time an FO is to t>e used. A deft.
)]..!,
nite benefit can be reelazed if NUC PR uses the IQTs sa Q,,,
intended and prescribed in the Procurement Manual. Another M.. u improvement can be made if site Power Stores order part.a as h.., c,
i inventories become low and not save t. hem up for a big order.
h.. '.,
4U (d) Item 8 is highly supported, and establishing a unifori
!! ? ",,
database with QA control could enable the use of the auto-l.
sated system for reordering of all inventory itene bot.h QA
~
j p.:
and non.QA.
This would be an effective method to eliminate the unne ce s s a ry s it e review performed on an ites each tisse p
h k{.L,.
Iit is reordered. Current empbaals by HMS, Power Stores, and
.\\
INUC PR should remain on QA program development.
31
- N i6 *
(e) Although itens 9 and 10 appear to be directed toward QA, the
~
report substantiates the need to train all personnel in the h
S q. '
p ro curement chain and to revise and standardize all proced-
- .t s
utes. NSRS fully agrees with this recommendation.
)
y, j
il
,j, ?
The Task Force report identifies s e,me real problem areas in the t*
procurement cycle and askes many v.ilid reco unendations. Immedia l
ate emphasis should be pieced on the more simplified solutions like eliminating unnecessary steps that could provide significent j'
improvesment s in the present system. An NSRS suggested solution presented in Attachment 1.
i to the problems with procurement is s
g 1
t i
4 i
i I
t.
s "g
- u..n.kw~ J. a.
.y.:in:
t>..m?.,.W. q. -:
o p ;.q w %,;. x.t.y.
- v..s.
m m.
n l S.Nisi, h M '"'"",,,ueig,,,i,q I
A.
are. retr w:...s,.m:.:t t..c s
r;..j y'y sn t
+
p... m..
-l
- y. E. Durus Croup Head, lastrument fiaintenance
- n,.%m..,...
y
' R. ColeJ. A. Coffey Site Director -
., I -
d
.c!A!,';.b.
j oqq U
- ;s t p
- ;,. ~
i (N. }$.[0,I-[?N.N" ' '
H'
.' J ha 8"#*I''
N'**'I*i' U"At
. D. CosD Read, Electrical Maintenance Group
\\p L
i
..s l
Quality Assurance Engineer k
( *N...
q) j
[0 plant Manager f
Q![t 's.
nos e,e Chemical Engineer y
gg /),tk'f.6. ~. ',,
R. E. Mabry n,t,,g,g, ogggg,,, p,,,ggere, 7.'
C' HI"*
'd l
M.g,6 ', 'i.
y'. R. Nebria Head, Engineering Group M *.
Supervisor, Modifications Section l
- ' f.. '. i,
J. C. Owen heterials Officer, Power stores I
%s i G f 4. " '
V. J. Percle Supervinor, Electrical Section l
i f
DM,5
'f*
J. R. Pittman Aseitstant Plant Manager, Maintenance
.f.l[j,y'7 R. D. Putman Asnistant Supervisor, Power Stores l
.Pg S. V. Solley Elcetrical Engineer, Electrical Maintenance V. C. Thomison Supervisor, Engineering N
V. M. Verses Specifications Engineer, Support Services
. i',
1 '
C. G. Wages Head, Mechanical haintenance d,
i j.
s.
B. H. Veeks Supervisor, Power Stures
@l T. T. Ziegler Branch Chief. Site Servi es
+
W. P. Ziruserman Materials Officer. Power Stores t
'.h B.
Sequoyah Nuclear Plant
{ '
i
\\ " i.
L. D. Alexander Supervisor, Mecbanical Modification
}
'I '.#,.'
R. E. Aleup Section Supervisor, Cunpliance Staff j
C. E. Brannon Supervisor, Power Stores T. L. Burke Mechanical Engineer
/
S. Butler Acting Supervisor, Tield Quality Engineerir.3 i
- h. L. Ceepbell Mechanical Engiocer. Mechanical Engie.eering (Mt 3
S. B. Campbell Materials Officer, rever Stores i
M. L. Crane t' nit Supervisor, Naterials Unit. Tield Services y
i F. D. Ebel Materists Clerk, Fever Stores g
. l *" '
R. V. Tortenberry Supervisor, Engineering w
L. J. Treeland Material Officer Power Stores J. R. Ilamilton Supervisor, Field Quality Engineering i
P. H.111tchcock Mechanical Engineer 1
~
'h
- 5. A. Kinsey Electsical Engineer D. L. Love Supervisor, Mechanical Maintenance Engineering
~
Section p
G. W. retty haterial Officer C
J. Robinsen Group Head, Modifications j
J. R. Staley Supervisor, Power Stores y
C. R. Stuts Quality Assurance Engineer. TQE p
$. W. Vickory.
Material O!!!cer, Materials Unit
'j P. E. Vallace Plant Manager 1
I j
fl g-o a
g-g
r N
~^
p__;
u waL 1
88h(J.,}' M.;u' W.s:..,
%p. s::.,y$,4*.i -
)
., ;.i 2
'?,' g.
- .U.9.,~N.'t i.
. Q$' g.'L.,rt..
43f,.
, T.Y
., dn:,..y f r Q,Q'3.g,, '
c.
Cesteat h 4.,..: :
,h;'ji.9$,,;.
D. A. Carter haterial Of ficer, Materis1s Maassement jhi,2 A.,
C. R. Favreau Mechanical Engineer
..#4,.',.)hfr;34".
R. D. Eicks
/
l Nteriale Of ficer, fiatarists Nnagement
.J. Hood b!,, *.,. Jh'.d ', '~
E Supervisor, Nuclear Power stores i
1.
j
'g,qj..y y M.' A. J've11 Assistant Supervisor, Power Stores
' i D. Eelley Cheutcal Engineer y.
,O,,'.
. E. Law Branch Chief, Quality Systems 3,,.s
- ,.q.7 T
H. Lewis Supervisor, Quality Assurance l
, ; *. ),:. Q,.
J. W. Habee Head, Laternal Supplier Evaluation Group j
"yj, g * * *; ',
E. W. h nsfield Supervisor, Power Stores g
....' M j L. Noerland
.e Supervisor, Materlate Management n.
R. J. Mullin Director, Division of Quality Assurance
.]
}-
- j{.',{
D. C. Nomading Branch Chief, tiaterials Management Servicee
. j
}7
.T'O. '
. m -.
Staff 85 G. Odell i
~
Supervisor, Management Services Staf f 1
i g,,
R. C. Parker Assistant Director, Division of Quality
{ M. I ~
f 'p
.s.
Assurance
[4 D. R. Parks Supervisor, Materla ts Analysis i.
J. 11. Pr a tt Nterial Of ficer, Materials Nnagement I"
K. R. Ramsey Quality Assurance Engineer j
, ', ' q, E. K. Sliger Supervisor, Radiological Emergency i
j, Preparedness Group
, :/,
J. R. Watson Quality Assurance Engineer j
G. E. Workman Nterials Of ficer, Materials fianagement W i j
Q.
D.
Purchasin2 j
L. N. Area Purchseing Agent, Nuclear TuelsSection I
2 D. A. Blackwell Supervisor, Hechanical Plant Equipament i
and Special Trojects Sections i
,j :
C. R. Lobson Supervisor, Nuclear Fuels Section T. W. Hannah Purchasing Asent, Cpen Market Electrical 3
Section l
J. E. Henesar l'urchasing Agent, Componenta Unit i
D. E. Henry Quality Assurance Engineer
}
^?'
E. C. Kidder Supervisor, Quality Assurance j
T. A. Love Assistant Director, PURC11 W. !!. Ma ry Purchasing Agent, Open Market Electrical Section i
D. Owen Administratise Assistant, Equ1Peent Procure-f ment Branch l.
C. S. Owensby Administrative Assistant, Materials Procure-ewat Branch
- 5. W. Talmer Purchasing Asect Open Market Construction Section f
G. D. Settles Supervisor, Cten Market Construction Section i
D. A. Seith Purchasing Agent, Nuclear Fuele Section l
J M. SmitA-Purchasing Agent. Open Market Electrical Section R. E. Sun.iarland Chief. Procurement Support Staff i
j P
I o
b 4
l
?
l,
i r
i I.
t 1W i-4
- 3. :7....g. 3.,' uc, -
a
.,s; 1
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. w.-
s.
M@W~W
-. :d ;.'-
y..;;,. :
1.
Otrle, et tante.orina
(:'
9 i
- *[.S e@', ;
- 4. F. Grant
- Electrical Engineer t
L. A. Johasoa flechanical tagineer, Tacility Support
I' i/.)
~ '.
and services
- k f."
A. V. Levie Nuclear Engineer, NIR, Design SuFport T. 8. Orr ~
Nuclear Engineer, NEB, Design Support.
r:
% C4...U J. L. Purkey Supervisor, Facility Support and Services f' W NI' A. C. Robertson Supervisor, tischanical section 2 D..,.: s T. B. Rosensweig Supervisor, Cable and liiscellaneous lr ' hi[,f 'l Equipment e
% g,.y' gs E. R. Taylor tiechanical Engineer, Nr.8, Special Support I
,l g:'
W. C. Wylie Electrical Engineer
?.
,7
- a
. f,, y..
T.
Office of the General Counsel iA.'...
.; d.~ [, ";
W. W. LaRoche Attorney
.S. 1 '-
VII. DOCLMENTS REVIEkT.D
),[D.
?,
J '.
A.
Requiettiens (Each requisition listed includes all associated doctmas-
'i ?
l
' i, s.t..".
tation.)
s 4
f
.s.
r.,-
t,.','
171173 835401 938284 943842 951129
~,
290205 925526-2 938298 945707 951133
' 3
..h,
322026 930478 940060 946728 951134
,(
334177 931892 940163 947434 951144 341210 93194I 940185 947454 951819
, Y,.,
343910 932925 940222 950455 955163 i*
Q 355436 932973 940276 950509 956101 1
i..<f 832041 932992 942925 951019 959025
}
[;'*.
833678 935570 942962 951023 959104 834705 935718 942988 951028 959122 834706
- 4
,g,.
8.
Fetulations Standerde ar.d Ur g Tier Documents I
3 I 10CTR21, Reporting of Def ec ts anu Nonroepliance"
- }
,4'{
'g 10CTR50, " Domestic Licensing of Production and litilization
!I Tacilities"
,ein Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction)"
l Reguistory Guide 1.29, "Setssic Design Classification"
'd
)j Reguistory Guide 1.33, " Wality Assursoce Program Requirements (Operational)"
9 Ragstatery Culde 1.38, " Quality Assurance Pequirements for Fackagies, Iblyptag, Receivina, Storage, and Kendling of Itese for Water-Cooked peclear fewer Floats" I
N d
1
.)
a s
g i,.e.
.3
.f, {
.4 4
.i i -
Re8vletery Outdo 1.58, "Quellfication of Nuclear Flant Inspection, Laaminattoa, and Testing Personas!"
... c.
4.v;}, ;g[.(
- Regulatory Guide 1.89, " Qualification of Class II Equipment for 1
Neclear Power F1 sate"
}
.'-v.r l
NNs6 p Regulatory Guide 1.123 " Quality Assurance Requirements for Centrol i
81 F
4.(($. D E of Procuroesnt of Items and Services for Nuclear Power Plants" k '
fi '%q p c.r.M W i-guRxo.0302, " Remarks Presented (Questions /Answere Discussed) at
-:+
l h;h Public Regional Meetings to Discuss Regulations (10Cm Part 21) f,*I,E;.( [ ',. ' '
for Reporting of Defects and hencomplisace" p
1, : * ?, o t
- f.Wh.);,- [.,, -
[.h*
NUREG-0588. " Interim staf f Position on Envirooment.41 Qualification of Sa f ety-Related Electrical Equipment"
.; y I kk.1
~
IE Bulletin No. 79 018. "Environeental Qualification of Class IE
- y{,
Equipment" 4'
IE Information Notice ho, 83-79 "Apparently leproper Use of f'
Comercial Grade Cocponents in Safety-Related Syst*me" j
V.
h
..g IEEE Standard 323A-1975 "!EEE Standard for Quai 6fying Class IE o*
f 8 '
Equipment for Nuclear Power Generating Stations"
[
l IEEI Standard 308-1980, "IEEE Standard Criteria for Class IE 3-Power Systems for Nuclear Power Generating Stations" p-
[t i:
f 4j.l "t;;
- IEEE Standard 336-1980, "!EEE Standard lasta11ation, Inspection.
j j, '* a and Testing Requirements for Class IE Instrumentation and Electric Equipment at Nuclear Power Generating Stations" p
j 4 s,
t 4 U
"?,,
IEEE Stenderd 467-1980, "!EEE Standard Quality Assurance Progree 3
) g
(.-
Requirements inr the Les tan anJ Hanuf acture of Class IE Instruments-y tion and Electric Equirment f or, Peuclear Power Generating Stations" 4f ILEE Standard 494-1975 "!EEE Standard riethod for Identification of Occuments Related to Class lE Equipeent and Systems for Nuclear
(
1 2
Power Generating Stations" 3
IEEE Standard 627-1980, "IEEE Standard for Design Qualification of e
Y Safety Systems Equipment Used in Nuclese Power Generating Stations" a
f
(
%g JEEE Standard 344-1975 "IEEE Recomunended Practices f or Seismic 3
Qualification of Class IE Equipment for Nuclear Power Generating s
1 S ta t ion s" q
fj 4
MSI M45.2-1971, " Quality Assurance Program Requirements f or 1
Noclear Power F1 sate"
{
M31/AS?fE M45.2.2-19 78. "Pec hssina, Shirpins. Receiving. Storage.
L' and Randling of flees lor Nucles Pcver Plants" h
15 N ARs t /Asrs N 45. 2.6-19 7 5. "Qua l i f t s.s t i on s o f I n s pe c t i on, La sa t a a t i on,
med Testias Perseasel for Nucles Pewer Plaats" a
u e
a e
/
)
I U N O' N fin ehr
- h k[.pg[4[ g
'4 6
. s;.
x i
AN31/A3M H5.2.9 1979, "Requireeents for Collection, Storase,
].
ese Maintenance of Quality Assursace Records for zuelear Power i
- (
Planta"
..,; g,.
QM...
' ANSI M43.2.13-1976, " Quality Assurance Requirements for Control L
/
f%g.gfy',
of Procurement of items and Services for Nuclear Power Plants"
,j h
,o r/D ANSI 18.7 1976, " Administrative Controls and Quality Assurance O*I*'-
for the Operational Phase of Nuclesr Power Plants" l
.,.d, ',.. *f '
ANSI /ASKE NQA-l=1979, " Quality Assurance Program Requirements for TU 6
Huclear rower l'iants"
[Y.'b.
- Topical Report TVA-TR75-1, Revision 8 " Quality Assursac. Program 7
?,f.;
Description for Design Construction and Operation" d
Operation Quality Assurance Manual. Dec.* ember 31, 1983 Procurement tianual, June 11, 1984
],'
ID-Q AP 4.3, "Trans f er of itema," September 21, 1983
.y B.
Divis ten of Nuclea r Power Procedure Manug js
'. h c,..
[."
Y,? -
N72A14. " Procurement and M terials Support Program," narch 30, 1983
- ?;
4 4
.. /g. '
N77A2, " Storage end Shelf Life Consideration for Materials with
./' )
Natural Aging Life," March 21, 1983 6".
1200R05 (H77 Alt.), "10CTR21 Evaluation and Reporting Requiscaents,"
3 October 26, 1983 l
.4 1601.02 (NMOISH), "Nurlear Plant bellability (Jat., Sy.ites (hrRDS),
Maintenance History and Class IF. Trad ins and Trendina - fleportsna Pailures of Components and Systres," December 9,1983 ll I
3
~r; TS 01.00.08.14.03 (N83M2), "Environe. ental Qualification of All s
g j
j
.f, Safety-Related Electrical Equipment (IE Bulletin 79-01B and NL' RIG 0588) " July 25, 1984 g
.l 6-9 N76A4, " Standards and bubstitutions Guides for Quality Assurance level III Items," June 9, 1982 g
N76A10. " Purchase Specifications for CSSC hetallic haterials, i
d Wire, and Cable Used Inside Prie.ary Contait'sent, Velding, and
]
Brasing Materials, Velve Tarts, and l' ump Parts," January 20, 1984 i
W82A17, "Equipeent and Material Storage Requrtements for Nuclear Power Stores," July 29, 1981, and Scrtember 7, 1984 Division of Nuclear Power Quality Control Inspector Trainina
~.
nausi, September 30, 1982 pg '
69 f
2..,
u
e
(
~
C, Browns Terry Nuclear Plant Proceduree 4
. /^, h '.' N
- ST 16.2, " Procurement," Juma 5, 1984 j k w t...
s, and f/* I h.h-RT 16,3, " Quality control of tiatorial Components, spare ".
U I
I.h' Services " July 20, 1982
.j
. ; %,s.
}*
jji.-+-
RT 16.4, " Material Componente and Spare Forte Receipt Handling,and Transf er," Jun Storage, Issuing, Return to Storeroom, 1:;c[
1 W.?
ET 16.9, " Procurement, Shipment and Receipt of Services and l,Y C,(t$.
ttaterial lavolving Power Service Shop." July 5,1983 E;:., 5 /, *.
RT 6.10. "TVA Tabricated Parts Used in CSSC." June 29, 1982 4
1, C h y:..';.'.' W Nd h oh -
BT Ett! 41, " Electrical neintenance Instruction 41 Ref uelina Platform and Jib Crane Chechout," Revision in ef f ect on Jane II,
'/ (,..n
.l T
1979
'h,. *,
/
D.
Sequoyah Nuclear Plant Procedureg SQA45, " Quality Control of Material and Farts and Services,"
,i
- i S'S-May 30, 1984 l
AI-11, " Receipt inspection. Honconforming items QA 1svel/Descrip.
tion Changes and Substitutions," finy 21, 1984 I
.3 E.
Of flee of Engineering Precedures
.i l
G 28, " Construction of Piping Systems f or Boiling Water Reacter k
Nuclear Power Plants," December 10, 1982 SS E18.11.04, " Quality Assurance Requir m at for Electrical or i
hechanical Equipeent Requa t ing Se tsmic Category 1 (L) Qualifice-r, tion," June 19, 1984 SS E18.10.01, "Envirernental Qua11f acetion Fequiremente for Safety-
,j Related Electrical Equipement," Augu t 29, 1984 SS-E18.11.02, " Quality Assurance Requirements for Safety-Reisted Electrical and Mecbenical (Non-ASME Sectica 111) Equipment,"
June 19, 1984
$5-E18.11.01, " Quality Assurance Requirements for ASMI Code, Section Ill Control Valves," May 26, 1983 S$-E18.11.03, " Quality Assurance Requirements (Certificate of Conformance)," June 19, 1984 s.
IDP N St,05, "Prereretien end Processing of Preliminary Design Change Requeste (P-DCR)," Ney 9, 1983
~
IDP-N $1.03, " Modification Implementation and Control Modificetten Tracklag Prograe," January 11, 1984
'.1 and s
(
I
-i
&y I...
h g
a l
l IDP N 34.01, "NUC PR Procurement Request to Ex pas," Mar 9,1983 IDP-N $0.02, " Division of Nuclear Power and Engineering Design -
l
-* 1.5.. l.l.
j 1, 8@ gY8...-
laterf aces " tiarch 1,1984
...,, e. !.,
1984
+
ID-QAP 2.4, "Co5 trol of Hodifications," March 30, g
, "( ~("., s. ; *.^
MEB-EP 23.5.5, "8pecification of tiuality Assurance Program Raquire*
mente for HER Requisitions," hay 27, 1983 i
l g
'.'.[- ;. P T.
Correspondence and Reports Hemorandue froe T. W. Chandler to J. A. Raulston dated August 13, r
y I
N4:
1984, " Browns f erry Nuclear Plants Units 1, 2, and 3 - Report to r
t*'
N?E*e' NRC Resulting Tree NRC heeting of hay 24, 1984, ce TVA's Eartiroe-sental Qualification Program," including attachments a
j f,1 si 3J' (T.EB 840813 938)
L
?f?h Test Report 17503-1 f ree Wyle Latx>ratories dated January 6,1984,
Control Equipment Consisting of Therminal Blocks, Pushbettoe Opera-
. Q, f
tors, Selector Switches and Contact Blocks and Various Cables" d-i l
Letter from Rithard T. Trosclair to N. M. 5prouse dated April 10, f+;
1972," Contract 71C-3-54360, 70C-61-54041 and 69C5-64545" k
Test Report 3359B dated November 19, 1971, loland Testing Labore-f.,
tories, Inc., "Peport of Test on (20) Switching Compocasta for 1
l er*
Cutler Hass>er" I
Memorandum f rom Eric kvaven to James P. Darling dated Augsat to, 1984, " Report of the Task Force for Studying and folving Procwo-l ment Problems in the Of fice of Nuclear Power (EUC PR)"
l
,0.
(LCO 840810 296)
{
r
.o Letter f rom R. H. Letor to George J. O' Dell dated April 6,1984, s
"Brief Procurement Proress Analysis of Pield Services Branch Purchase Requisition's Originated June I to December 31, 1982" (L12 840405 813) p Report CH-8200-14 dated February 25, 1983, " Environmental Quali-l fication Program," by O!! ice of Power Quality Assurance and Audit Staff (0QA 830225 703)
Nemorandum from H. J. Green to R. L. Lwepkin, Jr., dated May 10,
]
1983, " Quality Program Audit Report No. CH 8200-14" (0QA 830511 700)
Herort BP 8400-03, dated March 1,1984, " Browns Terry Nuclear Plant l
Procurement /Stierage Activities" (0QA 840220 701)
Memorandum from M. N. $prouse to H. J. Green dated November 6, 1981, " Procurement of Materiale, Components, Spare Parts, and Services N 0QAtt Part !!!, Section 2.1, dated APrtl 17, 1981" y
(EIS 811110 912) g i
.e l
g 9
.s u
.a
.fl
-J
$1
, Y' llenersessa free 4. A. Roller to Electrical Entiseerlag Files
+
. r-dated Answet 23,1983, "All Mutlear Plante - Developeest of a
( :m,*.'p.f.a q:,.
Cosgrohematie Laviremmental Qualification Program (CE4f)"
t
]
f'N t? /.y p'!.e'. v,
.Itseernaduas iten T. O. Campbell to Those listed dated Septeober 14, "j
. 5 ' ltT ;
4 1943, " Procurement of Clano 1E Euipment < A111tu lear Flants a i
...?7,,.T,i,f ;. -
Field Servlees". (L23 830815 884)
. y.d g
.,.s.
.> s.g j
- v'; y;, :
Memorandum from T. E. Spink to OQAB Tiles dated Octs.er 19, 1983,
- Neting of Special Evaluation Team - Environmental svalification 3
se...
of Saf ety-Related Equipment with Duke Power" R
{
A Memorandum from T. E. Spink to OQAB Tilets dated October 19, 1983, 5*
1 k ~y 0
" Meeting of Specist Evaluation Tesa - Environmental Qualification of Safety-Related Equipment with Cwoonwealth Edison Company (CECO)"
e y
}
Memorandum from H. J. Green to James P. Marlias, et al, dated July 23,1983, #8rowns Terry and Sequoyah Nuclear Safety Reelev e
i Boards' Annual Report, for 1982" Memorandum from R. L. Lumpkin, Jr., to T. A. Szczeepenski dated August 16,1983, "Browna Terry and sequoyah Nuclear Saf ety Review
,.yl Boarda' Annusi Report for 1982" (OQA 830816 700)
)
Hee.orandum f rom H. J. Green to James P. Darling, et al, September 22, 1983 "Brevns Terry and Sequoyah Nuclear Saf ety Review Boards' i
'8 (HSRB) Annual Report for 1982" (L69 830916 600) w n
Memorendum f roes P. R. Wallat e to those tieted dat ed February 15, f
U 1984, " Browns irrry. Sequoyoh, and Watt a Bar Nuclear F1snts -
.[,,
Maintenenre Act(vity of Clean it. Equipment" (Dr.5 840209 002) l
~#
Memorandus free Harold R. Denton, NFC, to Villiam J. Dirrks, NRC, dated January 21,1983, Equipment Qualification Program Plan" d
form TVA 45 f rom Ceorge J. Odell 1,o Dick Greith dated Deccaber 10, 1984,'"haterials Management Section Training Sessions"
- .t,1,
,5?'
Memorandsme f ror James L. Williams, Jr., to Those listed dated s
June 4,1984, "Premoting a Better Understanding of TVA's Purchaelag
.?1 Function" "i -
Memorandum f rom Herbert 5. Sanger. Jr., to W. T. Willie dated October 20,19M3, "Public 1.aw No. 98 Mandatory 45 Day Waiting i
Period - Procurement and Personst Services Contracts" j[
bemersedias free V. T. Vittis to Those listed dated October 31,
{
1983, "Tw611c 1.ew No. ai f2 - Mandatory AS-Day Waiting Period a
ACT - Agaylicative to Frecirement and Persosal Services Caetracta" flammereseas f ree Jameo L. V1111ame, Jr., to Reads of Of fices and
.(,'
Divisions dated Weemsber 3,1981, "robite Law 5.
98 theada-tery WDey We1 Lies Furied - Freestweest Castracts" i
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ss
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.g tenerseems frea Serbert 8. Saager, Jr., te nees listed dated Deensber 8,1943, 'Public Law pe.'94 73 = Mendetery 45-Der
^
Whittaa Period Act a Batest of TVA's vetentary compliance for
- 1 l'
.e...
Poser Program Centreets" f N.,a....,
.s. t v,-
Numersedum free E. N. Crime, Jr., to Those listed dated December 12,
)
.a s
l':14.'9 'ff. *, '
33e3, =pubige gav 3 33-73. Mandatery 45 Day Waities Feriod
? '. i.:
1 il
- r: 'Tf
,, j/4 :L.
Act. antest og tyA*e Velvatory Cesy11ance for Fewer Fregras
~'s'
,6.'V.;.-
, f.
'r'.,
Contratta" l
, 7, '., !;~ '.
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.i Meeersadum f ree W. F. Willin to Those Iteted dated February 3 l l'i: ke:(,r..
,,1 1984, "Public Law 98 Mandatory 45-nay Waities Period -
j
- .%,, '.s.
.f,
Application to Frecurement and Personal Services Centracts"
. '.. p"-
~st
- 3,, ;*
Hemorandum free J. A. Coffey to Those iteted dated February 29 1984, "Public Law 98 Mandatory 45-Day Waiting Period -
- *~l.,'.,',e Application to Division of Nuclear Power Procuremente"
.-: e e
pf '*,i s.
(L25 840301 460)
,-s,...
Memorandum f rom J. C. Holmes, Jr., to H. 5. Sanger, Jr., lated
! I, ;; '
March 15,1984, "Public Law No. 96 Mandatory 45 Day Waiting
r.
Frogram Contrarte" (Loo 840319 474)
Feriod Act - f.atent of TVA'n Voluntary Compliance for Power t..' ~
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fi
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- 3 I
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ess *
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$3 M.
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4
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m_.-
ATTACBERT I hi *. :.
SUGESTED 303.UTICII 70 F90C1mgM1lrf Ptosimi i
"f?$].'?(i.U' h2 Mas efters an approach te selving IrUC FR precurement problems starting L,';
?f.*7'i*I..h.*; with the beste procurement function. As attitude chasse sheeld occur
,.j;
. :s. pa.i.(e c., ehereby the preestemoet of items is considered for what it is--a very G S o # tapertant functies. Procurement within TVA is not simple and requires a o
f P.Qy! 7 level of espertise and beowledge not inherent in any positten currently at e,
)
' 's.. ' p.N the pl eet s.
The knowledge and experience must be taught and learned, d
2 N.*? ' ^. Freeestly, the time delays and inadequecte, are associated to a Israc
~ ' '
' estest with ladividuals learning on their owei how to procure things. h8R3
. j '3
'l ';I ! 9 5 '
'teeteede that p rocurement F itsee should be elevated in etsture and Lapertaaet to a professitinal level.
/, },;;'I To make the concept work, NUC FR should change its practice that everyone 3b
- caa and should be able to procure materials to one where a dedicated and JF,7 trained staff provides all procurement services. People need to know how to procuru things before they are f aced with the task. With proper train-1st, a significant number of learning errors could be eliminated and the pality of the procurement process, both from a materials standpoint as s
) '.
well as a time delay standpoint, could be improved. A training program on the entire procurement process to include TVA's procedures, quality requirementa, purchssing requirements, and Tederal procurement requirements I..
abould be developed and provided to personnel performing a procurement J.;'
function. Satisfactory coupletion of that training should be a requirement 1lp;g before en individual is allowed to procure anything.
'f't;.. ',
Am estension to the training requirement could be the establishment of a 7
3 W/,
group whose responsibility is the procurement of materials. In that con-
, h' * ,'
cept, engineers requiring items or services would go to the procurement stowP and specify what was needed. That group staf fed with the necessary N-i, espertise would, ' in turn, prepare the ne ce s s a ry procurement documents.
'^
3.'.i.c'.
define the saterial ops 8'ications, quality requirements, and provide a i.. %,
s.,
completed procurement peu.ge ready f or the approving of ficial, be it the
', Flaat finaager' or the Board of Directors. That staff would be responsible
/ *,..j,.,.
' :{.
- for assuring that the procurements were correct and require no further I
review or approval with the exception of the authorizing official (s) and
.a interf ace directly with FURCR. Power Stores personnel and their ordering
,t of stock items would not be included in this staf f but would work closely i
. i'.
with thee se procurements of stocked quality level materials.
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4 L..,
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ATTACHMENT D CONCERN IN-86-011-003/0E-QMS-1 BACK-UP-DATA A02830302008 2/24/83 NRC IE Info Notice 83-06 0QA830225703 2/25/83 QA Audit Report CH-8200-14 A02840705005 6/29/84 NRC IE Info Notice 84-52 Q01850312051 3/12/85 NSRS Report R-84-17-NPS Q01350312050 3/12/85 K. W. Whitt to J. P. Darling B45850521603 4/18/85 S. Johnson to Watts Bar Nuclear files A02850513006 5/08/85 NRC IE Info Notice 84-52-S-1 L12850520800 5/21/85 J. P. Darling to K. W. Whitt Handwritten Memo 8/12/85 J. Gilbert to K. Brown B22850925002 9/25/85 N. R. Beasley to G. R. Hall h
U00851025804 10/25/85 A. M. Qualls to J. C. Standifer B25851029003 10/29/85 J. P. Vineyard to N. R. Beasley B21851031002 10/31/85 J. C. S andifer to N. R. Beasley R32851105869 11/05/85 J. D. (arlson to G. R. Hall B22851106023 11/06/85 W. B. Jopf to Brown Ferry Eng.
,n Ef R45851031878 11/07/85 R. L. Lewis to C. R. Hall LO485118933 11/22/85 P. R. Wallace to H. B. Rankin 525851129015 11/29/85 J. P. Vineyard to N. R. Beasley L16851220825 12/20/85 J. E. Law to C. R. Hall R25860122878 1/21/86 F. R. Hall to H. R. Beasley B01860506002 5/06/86 F. E. Dicola to W. C. Drotleff L15860429801 5/21/86 S. A. White to "Those Listed" B41860606014 6/06/86 R. O. Barnett to C. A. Chandley W. S. Raughley I
6/23/86' W. C. Brocleff to "Those Listed" B44860619171 L298160701846 7/09/86 J. H. Millet of J. P. Stapleton p
L67860722863 7/22/86 S. A. White to "Those Listed" B45860725000 7/24/86 F. E. Dicola to "Those Listed" (Draft NQAM Procedure)
B70860806005 8/06/86 W. L. Elliott to Z. Kabiri D. Reia B22860808015 8/08/86 J. P. Stapleton to "Those Listed"
i.
.f.
e., '
o ATTACHKENT E h
i CONCERN XX-85-116-008 BACK-UP-DATA 1.
Appendix "B" to 10CFR50, criterion XVIII, Audits.
2.
NQAM, Part III, Section 5.1. Audits.
l 3.'
DQAI - 310; DQAI -'313, Rev. O and Rev. 1, DQAI - 104, Rev. O and Rev. 1 I
4.
Q. A. Reader Files, January through December 1985 5.
Q. A. Reader Files, July, August and September 1983 6.
Sequoyah Audit Reports:
SQ-8400-10 SQ-A-85-0003 l
SQ-8400-14 SQ-A-85-0008 SQ-8400-06 SQ-8400-09 SQ-8400-13 7.
Hulit-aite Audit Reports:
CH-8500-01 CH-8400-20 CH-8400-14 CH-8400-07 CH-8400-18 CH-8400-06 8.
Watts Bar Audit Reports:
WB-8500-02 WB-8400-02 QWB-A-85-0013 WB-8400-04 WB-8400-03 9.
Browns Ferry Audit Reports
?.
BF-8400-04 BF-8500-03 (1
BT-8400-14 QBF-A-85-0006
"'d BF-8400-08 g
10.
Homo to Site Directors from H. G. Parris, dated 6/13/84.
11.
Hemo to W. C. Bibb from C. W. Killian, dated 12/7/85.
12.
Hemo to R. J. Hullin from G. W. Killian, dated 5/30/85.
13.
Hemo to Quality Audit Branch from C. W. Killian, dated 11/14/85.
7 14.
Memo to H. L. Abercrombie from C. W. Killian, dated 9/23/85.
15.
Memo to C. W. Killian from H. L. Abercrombie, dated 7/31/85.
16.
Memo to H. L. Abercrombie from G. W. Killian, dated 9/23/85.
17.
Hemo to q.
A.
Audit File from C.
E.
- Bosley, C.
H.
Whittemore, and W. E. As11oger, dated 6/10/85.
18.
Hemo to Quality Audit Branch from G. W. Killian, dated 11/14/85.
19.
Quaterly DQA, Quality Problem Status Heating Hinutes, dated 6/17/85.
20.
Homo to "Tho'se Listed" from G. W. Killian, dated 4/19/85.
21.
Interoffice Mailing Slip, 45D, to all QAB from C.
W.
Killian, dated 5/10/85.
i b
i l
,e r
ATTACHMENI F e
ECSP CORRECTIVE Action Tracking Document i,[
(CATD)
'jp INITIATION 1.
Inunediate Corrective Action Required d/ Yes /[/ No 2.
Stop Work Reconunended
/~/ Yes /X/ No
~
3.
CATD No.
80101-SQN -01 4.
INITIATION DATE 9/8/86 5.
RESPO!!SIBLE ORGANIZATION: Office of Nuclear Power 6.
PROBLEM DESCRIPTION: /X/ QR /[/ NQR Procurement program did not assure-safety related materials, com-ponents, devices equipment, systems etc., procured by the Power Stores / Nuclear Plant Power Operations Process complied with applicable regulatory, design bases and qualification require-ments.
(Concern OE-QMS-1)
Action is being taken for the present procurements, however, the documentation reviewed and discussions held did not indicate what action is being taken on previous procured items.
t l
Attachment - Element Report 80101-SQN
/ /ATTACID1ENTS 7.
PREPARED BY NAME W.
E.
Bezanson DATE: _9 /K'/FM 8.
CONCURREllCE: CEG-il N E//M = f DATE: G/4/f(/
9.
APPROVAL: ECTG PROGRAM MGR
/
DATE:
et
?,M)
CORRECTIVE ACTION r
an
- m v 10.
PROPOSED CORRECTIVE ACTION PLAN
/X / ATTAClutENTS 11.
PROPOSED BY DIRECTOR /MGR DATE:
12.
CONCURRENCE: CEC-Il*
DATE:
7 r
SRP DATE:
ECTG FROGRAM HGR:
DATE:
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATIIRE TITLE DATE o
g,9
-