ML16341G522
| ML16341G522 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/07/1992 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341G520 | List: |
| References | |
| 50-275-92-09, 50-275-92-9, 50-323-92-09, 50-323-92-9, NUDOCS 9204240022 | |
| Download: ML16341G522 (34) | |
See also: IR 05000275/1992009
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos:
Docket Nos:
License
Nos:-
Licensee:
50-275/92-09
and 50-323/92-09
50-275
and 50-323
DPR-80 and
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Facility Name:
Diablo Canyon Units
1 and
2
Inspected At:
Corporate Office, San Francisco,
. Inspection
Conducted:
March 10-11,
1992 at Corporate office
Harch 16-17,
1992 in
RV office
Inspectors:
Approved By:
D. Kirsch, Chief, Reactor
Safety Branch
R.. Huey,
Enforcement Officer
S; Matthews,
gA Specialist,
VIB, NRR
srsc
,
se
,
eac or
a ety
rane
e
>gne
Summary:
s ection from March 10-17
1992
e ort Nos.
50-275 92-09
and 50-323 92-09
Safet
Issues
Mana ement
S stem
SIMS
Items:
None
Jesuits:
General
Conclusions
on Stren ths
and Weaknesses:
Strengths
In preparation
for the inspection,
the licensee
assembled
a
comprehensive
history of PGIl.E activities regarding the purchase
of the
sixth generator.
The history candidly identified the weaknesses
observed
in the procurement
processes.
Weaknesses
. The licensee's
corrective actions to resolve
a
nonconformance
report,
issued
in 1989, regarding
inadequate
supplier
audits failed to assess
the adequacy of the audits of NEI Peebles
Electric Products
Inc. - Cleveland,
and Peebles
Electric Hachines-
Scotland,
and. recognize
the potential
impact on the sixth generator
procurement.
In addition, the quality assurance
organization failed to
9204240022
92040S
ADOCK 05000275
G
0
identify certain irregularities in the procurement
process
such
as
supplier audit inadequacy,
the issuance
of a purchase
order to a
supplier who was not listed on the Qualified Suppliers List, and
performance of commercial
grade procurement
oversight
by a contractor
who had not developed
an adequate
commercial
grade procurement
and
program.
S fet
Si nificant Matters:
None
S mmar
of Violations and Oeviations:
This inspection identified two apparent violations of NRC requirements:
2.
Failure to comply with approved
procedures for dispositioning of
draft supplier audit findings.
Failure to implement appropriate corrective actions for inadequate
supplier
audits.'ll
t
t
This inspection
opened three
new open items.
getails
1. ~Ct
d
- M.'H. Fujimoto, Vice President,
Nuclear, Technical
Services
- R. C. Anderson,
Manager,
Nuclear Engineering
and Construction
.
Services
(NECS)
- H. R. Tressler,
Diablo Canyon Project Engineer,
NECS
J. A. Sexton,
Manager, guality Assurance
- J. C. Young, Director, Procurement guality Assurance
(P(A)
- U. A. Farradj,
Group Leader,
NECS
- J. E. Tompkins, Director, Nuclear Regulatory Affairs
- E. R. Kahler,
Group Leader,
Replacement
Parts
Engineering
(RPE)
- E. 'Walters,
Engineer,
RPE
- T. M. Packy,
Lead Auditor, P(A
C. Patrick,
Lead Auditor,
PgA
- H. 'S. Dobrzensky,= Senior Supervisor,
P(A
- -Attended the Exit Interview on Harch ll, 1992
2.
ur ose of Ins ection
The purpose of the inspection
was to
Assess
whether the licensee
had defined
and implemented
an
appropriate quality assurance
program for the procurement of the
generator portion of the sixth Emergency Diesel
Generator
(EDG)
unit,
Assess
whether the licensee's
quality assurance
and engineering
organizations
had acted responsibly in dealing with the generator
procurement-
and the problems identified,
~
Assess
whether the corrective actions in response
to
Nonconformance
Report
number DCO-89-gA-N007 were adequately
implemented for the generator
procurement,
and
~
Determine the circumstances
which contributed to the omission of
an audit finding, regarding
an undeveloped
commercial
grade
program
on the part of NEI Peebles - Electric Products,
Inc.
(P-EP) of Cleveland,
Ohio, from the final audit report
and
which remained
unresolved
by the licensee.
In order to accomplish this purpose
the inspectors
held discussions
with
the licensee's
engineering
and quality assurance
organization
regarding
the generator
procurement intent
and history,
and interviewed members of
the audit staff.
2
3.
enerator
oc rement (Inspection
Procedure
No. 92702)
ack round
i
b.
The inspector discussed,
with responsible
licensee
personnel,
the
philosophy
and intent of the generator
procurement for the sixth
EDG unit.
The licensee
indicated that
a basic premise
was that
the generator for the sixth
EDG would be identical to the
generators
installed
on the other five EDG units,
and the spare
generator,
procured in 1986-87.
The reasons for this desired
commonality primarily involved common spare parts,
common design
of the generator
and control panels,
common test
and maintenance
procedures,
and
common staff knowledge,
among others.
The licensee'tated
that the decision
was
made to procure the
sixth generator
from the
same manufacturer
who had manufactured
the other five generators,
and the spare,
and deal with the
qualification of the prime contractor/supplier
(P-EP)
and
manufacturer,
Peebles
Electrical Hachines
(PEH), of Edinburgh,
Scotland,
separately.
PG&E stated that they had
some confidence
that the generator quality would be acceptable
based
upon
engineering participation in audits
and satisfactory
procurement
and operation of fi.ve installed generators.
The licensee
stated
their belief that if anything
was wrong with the generator it
would be
made evident in the testing
and could be repaired,
and,
further, that their intent was to scrap the generator unit at any
.point that it became clear that the unit could not be deemed
qualified for service
and sufficiently reliable.
These decisions
were dictated
by schedule
considerations
which required having the
generator
tested
as
a unit with the diesel
in Canada
in Hay 1991,
and installed
and operational
by the completion of the
1993 Unit 2
refueling outage.
The licensee
purchased
the generator for the sixth
EDG unit from
P-EP,
a
10 CFR 50, Appendix B, supplier.
P-EP contracted with a
subsidiary,
PEH, located in Scotland, for the manufacture of the
generator.
PEH was not an Appendix
B qualified supplier.
Accordingly,
P-EP would need to assure that appropriate
commercial
grade
procurement
and dedication
processes
were exercised for the
generator
component parts.
Sixth
EDG Procurement
Chronolo
The licensee
supplied
and discussed
the following chronology.
~
In June
1988,
a Gulf States Utilities audit resulted
in
removing
P-EP from their Qualified Supplies List (QSL).
~
PG&E conducted audit
(89180S) of P-EP during July,
1989, in
an attempt to qualify P-EP for inclusion
on the
QSL:
Problems
were found, most notably that
a P-EP audit of PEH
was not an adequate
audit.
The audit was not sufficient to
qualify P-EP as
a gSL supplier of the generator.
PGIIE conducted
an audit of PEN during August
1989 in an
attempt to requalify PEN,as
a qualified supplier.
As a
result of problems found, the audit was
deemed
not
sufficient to requalify
PEN and was not listed
on the gSL.
PEN was removed from the gSL in January
1990
as
a result of
corrective action in response
to a nonconformance
report
regarding
inadequate
supplier qualification audits
(NCR
fDC0-89-gA-N007).
PGIIE conducted
another qualification audit (89295S) of P-EP
on December
11,
1989.
An interview with the lead auditor established
that
the audit was originally planned
as
a commercial
grade
procurement
and dedication
survey
and that the audit
was upgraded to an Appendix
B supplier qualification
audit after the audit was completed.
The
NRC
concluded that the upgrade
was not well managed
and
inappropriate.
The auditor indicated that
he only had slightly more
than
a week to plan the audit in addition to several
other duties at the time.
The
NRC concluded that this
seemed
an inadequate
amount of time to plan
an audit
of this scope.
The audit was
a one day audit,
an insufficient amount
of time to conduct
an audit of this scope.
The audit was
based
upon
a draft procurement
specification
(SP-D-Peebles/Rev.
3) which was not
issued until later,
on February 6,
1991.
The audit was conducted
even prior to the issuance
of
specification SP-D-Peebles/Rev.
2 on February
22,
1990.
The audit report was finally issued
on April
17,
1990.
The licensee
asserted
that the procurement
specification
issued
on February
22,
1990 accounted
for resolution of the findings of the audit;
however,
there
was. no documentation of this assertion.
The audit report was delayed
due to a two month
medical
leave
by the lead auditor.
The draft was
available in January
1990;
however,
comments of
licensee
management
were not able to be resolved
by
the lead auditor.
4
P-EP was ultimat'ely listed
on the gualified Suppliers
List on June
1,
1990 based
upon this one day audit.
. The purchase
order,
SP-D-Peebles/Rev.
2, was issued to
P-EP
on February
22,
1990, well before
P-EP was placed
on the
gSL in June
1990.
A draft Audit Finding Report
(AFR) was issued to P-EP
by the lead auditor on December
11,
1989.
The
AFR
identified that
P-EP
had not fully developed
a
.
commercial
grade dedication
program for PGLE
identified critical- parts.
This AFR was not tracked
to resolution or addressed
by the audit report, facts
which remained
unknown to the licensee until brought
to their attention
by the
NRC on February
20,
1992.
This is an apparent violation of procedure
gAA-WI-305,
which requires that the audit finding report
be
included in the audit package,
and procedure
gAA-WI-
317, which requires that audit finding reports
be
tracked in accor'dance
with procedure
gAA-WI-302.
(Violation, 50-323/92-09-01)
A followup audit was
deemed
necessary
by the audit
team
and was not done until August 1990,
about nine
months after the original audit.
The
NRC had the following conclusions
regarding this
audit and its relationship to future events.
C
The
NRC concluded that the audit was inadequately
planned,
and- inadequately
executed to adequately
address
the intended
scope.
The scope
was
inappropriately
upgraded,
after the audit, to be
an
Appendix
B supplier qualification audit instead of the
more limited commercial
grade survey, originally
planned;
The audit was conducted
using
a draft
procurement specification,
which would not be issued
until February
1991.
The purchase
order to P-EP
was
issued in February
1990, before the qualification
audit report was issued in April 1990,
and before
P-EP
was placed
on the
gSL in June
1990.
The followup
audit was not done until August 1990, after the
purchase
order was issued to P-EP
and after
P-EP was
placed
on the gSL.
The audit finding regarding
P-EP's
inadequate
commercial
grade dedication
program
was
never
adequately
resolved,
even though
PEN (a
subcontractor
to P-EP) procured generator parts
commercially
and supplied these to P-EP
as
a completed
generator.
PEM procured parts for the generator during early 1990.
PG&E had one supplier audit of PEM during this parts
procurement
phase.
A third party audit of P-EP was conducted
by Houston Light
and
Power during late July 1990.
Thirteen Audit Finding
Reports
were issued to P-EP.
An implementation audit of P-EP was conducted
in mid August
1990.
This was
a better planned audit than the December
1989 one day audit
and had,a longer duration.
P-EP was removed
from the
PG&E gSL on September
1,
1990.
The spare generator,
purchased
ear lier and in storage
at the
Diablo Canyon warehouse
was put on hold.
The procurement of
the sixth generator,
however,
continued,
apparently without
PG&E compensatory
measures
to compensate
for the removal of
P-EP from the gSL.
PG&E determined,
in August 1990, that
an Engineering
Evaluation of the sixth generator
was necessary
to determine
the adequacy of the generator
in light of the large
number
of supplier audit findings on P-EP
and
PEM.
The spare
generator
in the warehouse
on site was placed
on hold
pending completion of the Engineering Evaluation.
A joint P-EP/PG&E commercial
grade survey of PEM was
conducted
in October
1990.
The
PG&E team consisted of
quality assurance
and engineering
personnel.
The audit
resulted in six audit finding Reports
and
a request for an
Engineering Evaluation to evaluate
the impact of the
findings on the adequacy of the sixth generator.
Assembly of the generator
occurred at
PEM during the period
of October
1990 through February
1991.
During this period
PG&E had source
inspectors
at
PEM on two occasions
to
monitor the generator quality and testing.
The generator
was shipped in late February
1991.
The final Purchase
Order (SP-D-Peebles/Rev.
3) was issued to
P-EP
on February 6,
1991.
At this time the generator
assembly
was essentially
complete
and testing
was in
progress.
P-EP was reinstated
on the
gSL for a One-Time purchase
on
March 1,
1991, after the generator
was constructed
and
shipped
from PEM.
A verification visit to P-EP
on March 13,
1991 found that
the
P-EP corrective actions applicable to a one-time
purchase
were not acceptably
implemented.
A second
6
verification inspection to P-EP during July 1991 found that
P-EP
had adequately
implemented corrective actions
applicable to a one-time purchase.-
PG&E issued the final Engineering
Evaluation of P-EP
and
PEH
activities
on October 31,
1991, concluding that the spare
and sixth generator
were acceptable.
Com arison of PG&E's Audit
din s at
P-EP
and
P
H to the
RC's
Ins ection F
at
-
d
H (92702)
The
NRC conducted
an inspection of P-EP, in August of 1991, to evaluate
P-EP's production of an emergency
As a
result of this inspection,
documented
in Inspection Report (IR)
99900772/91-01,
the
NRC issued
a Notice of Nonconformance to P-EP that
identified four areas
where P-EP's activities failed to comply with NRC
51
5
1
App
dt tt
Tttl
15, ftt ~df
d
P t5
tt
CPRP
5T.
1
d td
inspection of PEH, in September
of. 1991 to evaluate
PEH's manufacture of
the generator for PG&E.
As a result of this inspection,
documented
in
IR 99901065/91-01,
the
NRC issued
a Notice of Nonconformance to
PEH that
identified two areas
where
PEH's activities failed to comply with P-EP's
expectations
necessary
to support certification that the generator
complied with the requirements
of Appendix
B to
In its response
to IR 99900772/92-01,
dated
February
12,
1992,
provided (1)
an itemization of the NRC's issues identified in IR
99900772/91-01,
(2) the corresponding
PGEE audit findings,
and (3) the
compensatory
actions taken
by PG&E to. resolve the findings.
PG&E's
response
did not address
the NRC's findings 'in IR 99901065/91-01
(PEH).
The team's
review of certain sections of PG&E's response
resulted
in the
observations
described
below.
a.
Section III - Additional Information on
P-EP related
0 en Items
Identified in NRC
R 50-
3 91-202
This section of PG&E's response
discusses
three concerns
related
to the generator identified in the NRC's letter to PG&E, dated
November
15,
1991, which transmitted
IR 50-323/91-202.P
(1)
otor
Po
e
Ha net Mire:
PG&E stated that
P-EP
had reported
that it is evaluating the impact of the varnished-wire that
was
used in the fabrication of the generator's
pole windings
(P-EP
had specified the use of unvarnished wire).
P-EP had
not completed its evaluation at the time of this inspection.
This issue
was identified by the
NRC during its inspection
of PEH.
This issue
was, not identified by PG&E.
(2)
Bakelite Electrical
Se aration
Rin
The commercial
grade
bakelite electrical
separation
ring was
used
as
a load
bearing component-part
of the rotor shaft support
assembly.
(3)
PG&E stated that it agreed that the ring is part of the
support
system of the bearing housing,
due to the sandwich
design,
and lack of any known failure of this design.
The
mechanical
strength
was not considered
a critical design
characteristic.
PG&E, however, did not demonstrate
to the
team
an engineering
evaluation to substantiate
this
conclusion
or that assured
the adequacy of the comaercial
grade item to perform its function in support of the rotor
shaft assembly.
This issue
was identified by the
NRC during
its inspection of PEN.
This issue
was not identified by
PG&E.
c
'c tion o
Cr t ca
o
one ts
PG&E stated that
although the list of 27 critical items, identified in
Revision
3 of its purchase
order
(PO) to P-EP was not
signed-off until after the generator
was completed,
these
items were examined during the October
1990 audit of PEN.
However, not all of the
27 critical items were examined
during the audit; the audit examined only a sample
(seven
items) of the identified 27 critical items.
Revision
1 of PG&E's'O to P-EP incorporated
a list of 14
critical items that, according to PG&E, were identified by
P-EP
as
a list of critical items that ~a
be procured
and
dedicated
by P-EP then supplied to PEN.
However, the
auditors that conducted
the
December
1989 audit of P-EP,
the
associated
audi.t documentation,
and associated
correspondence
appeared
to indicate that the critical items
were developed
by PG&E's technical staff that supported
the
December
1989 audit.
This issue
was identified by the
NRC
during its inspections of P-EP
and
PEH.
Section
V Additional Information on 0 en-
tems
denti .ied in
RC Ins ection
Re ort No..99900772
91-01
f
This section of PG&E's response
reviews the nonconformances
and
the unresolved
item identified in IR 99900772/91-01.
onconformance
99900772
91-0 -01:
This nonconformance
identified that
P-EP failed to (1) establish
adequate
measures
to control
changes
in design, materials,
and
.manufacturing
processes
commensurate
with those controls
applied to the original design,
(2) provide for performing
design verification of the changes
in design, materials,
and
manufacturing
processes,
(3) demonstrate
that the changes
in
the design
were controlled commensurate
with the design
controls applied to the original design,
and (4) demonstrate
that the original design basis
had
been correctly translated
into revised specifications,
drawings,
procedures,
and
instructions.
0
8'G&E
stated,
in part, that its audit of P-EP in August
1990
(Audit 90197S) identified corresponding
programmatic
findings, documented
in its audit finding report
(AFR)90-067.
PG&E's response
stated,
in part,.that the
evaluation of design
changes
and specifications
and
procedures
equivalency
was not required prior to the
1984
time frame since the issues
requiring this review were
associated
with a lack of formal interface
between
P-EP
and
PEM.
This nonconformance,
however, identified issues. with
P-EP's design control that were independent of the
P-EP
and
PEH interface.
PG&E reported to the team that it had reconsidered this
response
in part because
of the like-for-like guidance
provided by the
NRC in Generic Letter (GL) 91-05,
"Licensee
Commercial-Grade
Procurement
and Dedication Programs."
reported that its response,
compensatory
actions,
and
engineering
evaluation will be revised to evaluate
the
changes
in design, material,
and the manufacturing
process
since the original generators
were supplied in 1969.
This evaluation is necessary
to determine if any of these
changes
could impact the functional characteristics
and,
ultimately, the generator's'ability
to perform its required
safety function.
The revised engineering
evaluation will be
evaluated
by the,NRC during
a future inspection.
onconformance
9990077
91-0 -0
This nonconformance
identified that
P-EP failed to:
(1) establish
adequate
measures
to contro1 the activities between it and its sister
organization,
PEM, that consisted of the review, approval,
release,
distribution,
and revision of documents
involving
their respective
design interface,
(2) demonstrate
that the
results of PEM's design translation activities were
equivalent to the design requirements
specified -by P-EP,
(3)
adequately
document the critical requirements
or acceptance
criteria compared during the equivalency evaluation,
and (4)
adequately
document the results of the equivalency
evaluation or other bases
to support
P-EP's
conclusion that
PEM's procedure's
and specifications
were equivalent.
PG&E stated,
in part, that its Audit 90197S identified
corresponding
programmatic findings in AFR 90-068.
However,
this
AFR identified (1) that P-EP's external
audit/evaluation
program used to qualify suppliers (e.g.,
PEH)
was not adequate
to comply with PG&E's specification
and (2) that P-EP's quality program did not include
provisions for the dedication of commercial
grade items.
PG&E did not identify the
P-EP
and
PEH interface
issue
addressed
in this nonconformance until the
P-EP/PG&E audit
of PEM conducted
in October
1991
and documented
in P-EP's
Audit Report 9003.
Audit Report
9003 identified this issue
0
in AFR 9003-4
(P-EP
and
PEN interface)
and
AFR 9003-6
(equivalency of PEM procedures
and specifications to P-EP
procedures
and specifications).
~
PGIIE's response
stated,
in part, that in conjunction with
P-EP, it is formulating
a plan for identifying additional
reviews
and documentation
requirements
needed to ensure
the
adequate
resolution of the NRC's nonconformance.
onco formance
990077
91-01-03:
This nonconformance
identified that
P-EP failed to:
(1) establish
adequate
measures
to provide for the selection
and review for
suitability of the application for materials,
parts,
and
equipment that were procured
as commercial
grade
items
and
were essential
to the generator's ability to perform its
essential
to the generator's ability to perform its intended
design
and safety-related
function; (2) ensure
the
suitability of the stator coil's resistance
temperature
detectors,
slip rings,
adhesives,
and mounting sleeve
insulator for the slip rings;
and (3) ensure
the suitability
of the materials,
parts,
and equipment
PEN procured.
PGEE stated that its Audit 90197S identified corresponding
programnatic findings in AFRs90-068
and 90-069.
However,
PGEE first identified the programmatic
issue
addressed
in
this nonconformance,
that P-EP's quality program did not
include provisions for the dedication of commercial
grade
items, in its December
1989 audit of P-EP,
as documented
in
draft AFR No. 3.
PGKE's utilization of the December
1989
audit
and its results is discussed
in paragraph
3.b of this
report.
The adequacy of PG&E's response
and corrective actions with
regard to the NRC's findings related to certain critical
items (e.g.,
the stator coil's resistance
temperature
detectors,
slip rings, adhesives,
and mounting sleeve
insulator for the slip rings) will be evaluated
by the
NRC
during
a future inspection.
onconformance
9990077
9'-01-04:
This nonconformance
identified that
P-EP failed to establish
adequate
measures
to ensure
(1) that activities affecting quality were
prescribed
by documented
instructions,
procedures,
or
drawings;
(2) that activities affecting quality were
accomplished
in accordance
with these instructions,
procedures,
or drawings;
and (3) that instructions,
procedures,
or drawings include appropriate quantitative or
qualitative acceptance
criteria for determining that
important activities were satisfactorily accomplished.
P-EP
also failed to demonstrate
that the activities affecting
quality (1)" to fit the dovetail rotor pole assemblies
to the
rotor spider
assembly,
(2) to perform the brazing required
0
10
to fabricate the rotor spider assembly,
and (3) to perform
brazed joint spliced-connections
in the field coil winding
were documented
or accomplished
in accordance
with
instructions,
procedures,
or drawings that contained
quantitative or qualitative acceptance criteria and were
equivalent to those specified
by P-EP..
PG&E stated that its Audit 90197S identified corresponding
programmatic findings in AFRs90-068
and 90-072,
and in
P-EP/PG&E's Audit Report
9003,
AFR 9003-5.
Although AFR
90-068 identified (1) that P-EP's external audit/evaluation
program used to qualify suppliers (e.g.,
PEH) was not
adequate
to comply with PG&E's specification
and (2) that
P-EP's quality program did not include provisions for. the
dedication of commercial
grade items, neither of these
issues
are applicable to the issues
addressed
in this
nonconformance.
AFR
90-072 identified that P-EP's internal.
audit program was not adequate
and, therefore, it also did
not address
the issues
in this nonconformance.
AFR 9003-5
addressed
the failure of PEN's procedure-to
provide for the
calibration of the crimping tool or inspection of the
crimped connections.
PG&E's response
with regard to the
applicability of AFRs90-068,
90-072,
and 9003-5 did not
adequately
address
the issue
addressed
in this
nonconformance.
PG&E also responded
that detailed procedures
were not
required for the activities that affect safety during the
fabrication of the rotor pole spider assembly,
as these
operations
were part of normal
shop practice.
The
NRC team
determined that these operations
were part of normal
shop
practice
when the generators
were manufactured
in P-EP's
facility, however,
these
operations
were not part of PEN's
normal
shop practice, particularly since it was
PEN that
requested
the guidance
from P-EP.
PG&E 'added that if the
rotor pole was not assembled
correctly,
.the result would be
.
excess vibration, particularly during the overspeed
portion
of the test.
The basis for PG&E's conclusion
was not
demonstrated
to the team (i.e., vibration monitoring data
recorded during the overspeed
test
"nd post-test
inspection
documentation of the rotor pole spider assembly).
The adequacy of PG&E's response
and corrective actions with
regard to the NRC's findings related to the welding of the
rotor pole spider
assembly
studs
and spliced connections
in
the field coil windings will be evaluated
by the
NRC during
a future inspection.
Unresolved
tern 99900772
91-0 -05:
This unresolved
item
addressed
the concern that P-EP's original quality assurance
manual
((AN-100), in effect during the design,
manufacture,
and test of PG&E's generator,
did not include measures
to
11
adequately
control all of the activities affecting the
quality and safety-related
function of components
and parts.
Although P-EP's
second quality assurance
manual
((AM-101)
superseded
(AM-100, it contained
several
weaknesses
that
required strengthening
before its implementation.
Because
the team did not evaluate
the implementation of (AM-101,
this concern would be evaluated
in more detail during
a
future inspection.
PG&E's response
that this Unresolved
Item did not impact
their generator,
since
9AM-101 is not applicable to this
PG&E procurement,
is considered
adequate
and
no further
discussion of this issue
by
PG&E is required.
de uac
of PG&E's
n ineerin
Evaluation.
(92702)
Section
V,
"PG&E Engineering
Evaluation of P-EP for Purchase
of Sixth
Generator," of PG&E's response,
dated
February
12,
1991, provided
an
overview of the engineering
evaluation
performed
by
PG&E to quality P-
EP,
and according to
PG&E it includes
(1)
a description of PG&E's
procedural
requirements,
(2)
a summary of the
P-EP
NEMP 12.4 Engineering
Evaluation,
Revision 0,
and (3)
a summary of the additional
information
incorporated into Revision
1 of NEMP 12.4.
The team's
review of certain
sections of PG&E's Engineering
Evaluation resulted in the observations.
described
below.
a
~
Product
Performance
Evaluation
b.
This section of PG&E's Engineering Evaluation provided
an
evaluation of the history of P-EP's generators
in the nuclear
industry.
To determine
whether the history of P-EP's generator
affects the quality of the
new generator,
PG&E reviewed the
following documents:
NPRDS reports,
10 CFR Part 21 reports
and
utility reports, Bulletins, Letters,
SERs,
SCERs,
LERs, Restricted
Equipment List,
NRC IRs,
and
GIDEP reports.
The team's
review of this portion of PG&E's Engineering
Evaluation
determined that where the evaluation related to the
same,
or
similar, parts or component-parts
identified by
PG&E as critical
items,
the evaluation
lacked sufficient detail
addressing
the
correlation of the item reviewed to the item installed in new
generator.
Specifically, the evaluation did not. address
the part
and component-part
issued identified in IR 99900772/91-01
and
IR
99901065/91-01.
Su lier uglification
This section of PG&E's Engineering
Evaluation provided
a technical
evaluation of PG&E's audit findings of P-EP
and
PEM, evaluated
the
qualification of the
new generator
purchase,
and determined
the
acceptability of the stocked
spare.
The list of critical items
were separated
according to what facility procured
them,
because,
12
according to POKE, the items supplied
by
PEN were qualified by the
P-EP/PGKE Audit 9003
and the Engineering Evaluation, while those
items supplied
by P-E were qualified by P-EP's coaeercial
grade
program
and the Engineering Evaluation.-
The team's evaluation of this section of the Engineering
Evaluation resulted in the following observations:
PGKE's basis for determining that its list of 27 critical
items represented
a complete list of the generator's
critical items was not adequately
demonstrated.
Since the
team believes that there are conflicting versions of how and
who identified the critical items, it is therefore
necessary
to evaluate the engineering
basis for the list of critical
items.
As reported
by PGKE, the technical
evaluation of the Audit
90197S findings relating to design control will be revised
to evaluate
the changes
in design, material,
and the
manufacturing
process
since the original generators
were
supplied in 1969.
~
, The evaluation of P-EP's
and
PEH's commercial
grade
dedication activities for the specific parts
and component-
parts identified in IRs 99900772/91-01
and 99901065/91-01
will be evaluated
in detail during
a future inspection.
GKE's
Com ensator
Actions for NRC's
s ection Findi
s at P-
P and
PEM. (92702)
PG&E's compensatory
actions for all of the NRC's specific findings
related to critical parts
and component-parts
of the generator that were
identified during inspections of P-EP
and
PEN will be evaluated
in
detail
by the
NRC during
a future inspection.
Review of Licensee Actions to Address
Su lier Audit Findin
s (92702)
Previous
NRC inspections of P-EP
and
PEN during August and September
1991, identified several significant deficiencies
in the implementation
of 10 CFR 50, Appendix
B qua'lity assurance
program requirements,
as
w ll
as identifying some specific technical deficiencies
in the products
being supplied.
One of the objectives of these
NRC inspections
was to
evaluate
whether
PG&E had implemented appropriate
measures 'for assessing
the adequacy of its supplier quality assurance
(gA) programs
and
responded
appropriately to any findings resulting from such assessments.
In this regard,
the inspectors
noted that
PGKE had identified supplier
gA program problems in August
1990 that were similar to the programmatic
concerns
subsequently
identified by the
NRC.
Accordingly, the
inspectors
reviewed the actions
taken
by the licensee
in response
to
their August
1990 findings,
as well as evaluating whether the problems
13
identified in August 1990 should
have
been identified earlier in the
procurement
process
(especially in light of significant lessons
identified during
a comprehensive
PG&E review of supplier procurement
problems in 1989).
a 0
'censee
Res
o se to
s
90
S
lie
ud't
d
s
As noted
above,
during an August
1990 audit of P-EP (Audit
, 90197S),
PG&E identified numerous significant programmatic
,
deficiencies in the supplier's
implementation of Appendix
B
quality assurance
requirements.
PG&E recognized that the results
of this audit conflicted with the conclusions of an earlier audit
performed in December
1989 (Audit 89295S),
which served
as the
supplier qualification audit for the February
1990 placement of a
purchase
order with P-EP for a Diablo Canyon diesel
generator.
Accordingly,
PG&E initiated an Action Request
(A0201828) in August
1990 to assess
the reasons for the differences
between the
1989
and
1990 audit results.
This assessment
was subsequently
upgraded
to a safety related guality Evaluation
(f0008302) in January
1991
and
a Nonconformance
Report
(NCR 92-N004) in February
1992.
4
The inspectors
concluded that the scope
and corrective actions
associated
with NCR 92-N004 were too narrowly focused only on, the
specific shortcomings of audit 89295S,
instead of recognizing the
broader
and more generic significance of other potentially
inadequate
audits conducted
between July 1989
and December
1990.
In particular, the inspectors
noted the following:
(1)
PG&E identified that Audit 89295S
and the subsequent
placement of the
P-EP purchase
order were deficient in
several
respects.
In particular: audit planning,
scope
and
specification
bases
were deficient; audi,t conclusions
were
based
on inadequate
objective evidence;
licensee
procedures
for disposition of preliminary audit findings were violated;
and procedures
requiring suppliers to be on
a gualified
Suppliers List prior to purchase
order placement
were
'iolated.
(2)
(3)
Each of the Audit 89295S findings are similar to findings
associated
with an earlier comprehensive
PG&E evaluation of
supplier audit deficiencies
issued
in July 1989
as
an
Nonconformance
Report
(NCR 89-N007).
Final corrective
actions associated
with NCR 89-N007 were not signed off as
being fully implemented until December
1990.
Since Audit 89295S,
which occurred in December
1989, clearly
did not implement the lessons of NCR 89-N007, the inspectors
concluded that it is likely that other audits performed
during the August
1989 through
December
1990 time period
may
be similarly flawed.
14
b.
During the exit meeting,
the licensee
agreed with the inspector's
conclusions
and committed to expand the scope of NCR 92-N004
corrective actions to include
a review of -all audits performed
during the August
1989 through
December
1990 time period.
Earlier 0
ortunities to Identif
Su lier Procurement
oblems
As noted
above,
PG&E had identified many of the types of audit
deficiencies
associated
with Audit 89295S several
months prior to
performing the audit.
However, these
lessons
were not factored
into Audit 89295S,
although the audit served
as the basis for
placing
a major, safety related .purchase
order.
Although it is
recognized that full implementation of NCR 89-N007 lessons
were
continuing throughout the July 1989 to December
1990 time period,
PG&E failure to implement
any of those lessons
during Audit 89295S
appeared
to the inspectors
to be
a significant missed opportunity.
This failure precluded timely identification and correction of the
significant problems that were subsequently
identified in July and
August 1990, well after significant portions of the purchase
order
had already
been completed.
As a result of the inadequate
1989
audit,
a safety related
purchase
order was placed with P-EP in
February
1990, which did not meet
10 CFR 50, Appendix
B quality
. assurance
program requirements,
as specified in the purchase
order.
documents.
This deficiency was not identified until receipt of an
audit from Houston Light & Power in July 1990 (disqualifying .P-EP
for safety related procurement),
and
a similarly disqualifying
PG&E audit performed in August 1990.
Failure to implement timely actions to preclude recurrence of the
supplier audit deficiencies
addressed
by NCR 89-N007 for Audit
89295S is an apparent violation of 10 CFR 50, Appendix B,
Criterion
16 (Violation, 50-323/92-09-02).
Failure to ensure
proper implementation of quality assurance
requirements
associated
with the purchase of safety related
equipment
from P-EP is an
apparent violation of 10 CFR 50, Appendix B, Criterion
7 (Non-
cited Violation, 50-323/92-09-03).
This violation will not be the
subject of NRC enforcement
action because
the licensee's
efforts
in identifying and correcting the violation meet the criteria
specified in Section VII.B.2 of the Enforcement Policy.
During the exit meeting,
the inspectors
emphasized
several
points
relating to the similarity of this inspection's
findings with those
described
in Inspection
Reports
50-323/89-22
and 50-323/89-27.
These
similarities appear to indicate that
PG&E has not fully implemented
some
of the lessons that should
have
been learned'rom
the significant
guality Assurance
program deficiencies that were addressed
during those
inspections.
In particular, the inspectors
noted that:
a.
One of the major findings of the
1989
NRC inspections
was that
PG&E had too narrowly limited the scope of their review of
inadequate
supplier audits to only those
performed
by contractors,
rather than also addressing
similar deficiencies
in
PG&E performed
15
b.
audits.
As discussed
above, this inspection
noted that the scope
of PG8E's current review of supplier audit deficiencies
(NCR 92-
N004) was also too narrowly focussed.
Another finding of the
1989'NRC inspections
was that
PGLE audit
personnel
were experiencing difficulty raising concerns to their
gA supervision,
resulting in significant program deficiencies
not
being properly evaluated
and resolved in a timely manner.
During
interviews. with PGLE audit personnel
during this inspection, it
again
appeared
that auditor concerns
associated
with the scope
and
definition of Audit 89295S were not properly evaluated
or resolved
in a timely manner.
Although the interviewed personnel
indicated
that they believe that the circumstances
which resulted in those
problems
have
now been corrected,
the fact that they occurred
warrants continuing
PG&E attention to preclude recurrence.
it
terview
The inspectors
discussed
the findings of the inspection,
as indicated
above, with members of the licensee's staff,
as indicated in paragraph
1, at the conclusion of the inspection
on Harch
11,
1990 at the
Corporate Office.
The licensee
acknowledged
the inspection findings and
again reiterated that their management
had determined
to procure
a
generator alike those already installed at Diablo Canyon,
in full
recognition of the problems
found with the quality paperwork of the
suppliers,
and do whatever
was necessary
to later establish
the quality
and acceptability of the generator
by Engineering
Evaluation
and
testing.
The licensee further stated that, in the event that it became,
or becomes,
apparent at any point that the generator
cannot
be qualified
for service, their intent was to scrap the machine short of accepting
and placing the machine in operation.
0