ML20210H094
| ML20210H094 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/02/1987 |
| From: | Joyce J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| 80101-SQN, 80101-SQN-R05, 80101-SQN-R5, NUDOCS 8702110380 | |
| Download: ML20210H094 (113) | |
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L- ~~ ---TVA EMPLOYEE CONCERNS REPORT NUMBER: SPECIAL PROGRAM 80101-SQN REVISION NUMBER: REPORT TYPE 5 Element Report TITLE: PAGE 1 0F 15 Quality Assurance Program Adequacy REASON FOR REVISION: Rewritten to incorporate SRP and TAS comments. Revision indicators are shown on each page to indicate revision changes. Note: Sequoyah Applicability Only PREPARATION PREPARED BY: WILLIAM E. BEZANSON f r~ /07/f/ IfATE' GNATURE REVIEWS PEER: M c& t/ u ' 87 DATE (G # SIGNATURE TAS*
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CONCURRENCES m / / / > vs - . Ce d M M M /-274 7 SRP h W h [M M Z -2
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APPROVED BY: p [2 1, _ N/A MANAGER OF NUCLEAR POWER DATE ECSPMANAGER[/ 6 ATE /' CONCURRENCE (FINAL REPORT ONLY)
*SRP Secretary's Signature denotes SRP concurrence are in files.
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y) REPORT NUMBER: ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER: 5 TITLE: Quality Assurance Program Adequacy PAGE 2 0F 15 '*- 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction This report re flec ts the results of the Quality Assurance Category Evaluation Group (QACEG) investigation of six employee concerns which were identified by the Tennessee Valley Authority (TVA) Watts Bar Employee Concerns Special Program. These concerns were evaluated for the Sequoyah Nuclear Plant (SQNP) as two concerns were determined to be Sequoyah specific with the remaining concerns designated as generically applicable to SQNP. 1.2 Description of Issues The conditions reported by concerned employees (Attachment A), and as noted be low, were grouped by issue under this element since they pertain to the adequacy of the Quality Assurance (QA) Program at SQNP. 1.2.1 Issue - Excessive Paperwork and Procedures In the process of emphasizing the importance of " Quality", TVA has interpreted quantity as the meaning, e.g., excessive amount of paperwork and procedures (Concern BFM-86-002-001, dated January 17, 1986) Amount of procedures and paperwork is the principle concern at Sequoyah not the quality of work. (Concern MRS-85-001, dated June 23, 1986) 1.2.2 Issue - Procurement Requirements Not Invoked
.TVA Material suppliers are not required to invoke QA requirements on sub-tier suppliers. (Concern IN-86-011-003, dated November 12, 1985)
Power Stores / Nuclear Plant Power Operation procurement process (Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1) does not assure applicable requirements (regulatory, design bases, qualification etc.) are being met. (Concern OE-QMS-1, dated July 26, 1986) 1.2.3 Issue - Nuclear Quality Assurance Manual Requirements Not Complied With TVA Nuc lear plants are igne t ing the QC Program from the Nuclear Power Of fice (NQAM) and are writing their own program. , (Concern WBM-86-004-002, dated January 24, 1986) o
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' ELEMENT TYPE:- 80101-SQN Element Report REVISION NUMBER: TITLE: 5 Quality Assurance Program Adequacy PAGE 3 0F 15 1.2.4 Issue - Management Pressure is Restricting The Audit Functions Quality Assurance Management pressures auditors to close audit deviations be fore the auditor is satis fied that adequate correc tive action has been implemented. (XX-85-116-008 dated February 21, 1986) These perceived conditions noted above established the basic element for this evaluation as " Quality Assurance Program Adequacy". 2.0
SUMMARY
2.1 Sumary of Characterization of Issue The employee conce rns were grouped into the e lement of " Quality-Assurance Program Adequacy" because the conditions specified in those concerns pertain to the adequacy of the Quality Assurance (QA) Program being implemented at SQNP. 2.2 Sununary of Evaluation Process \ During the course of this evaluation, Appendix B to 10CFR50 and " the following TVA documents - were review to determine requirements and commitments as they apply to SQNP and this issue: Final Sa fe ty Analysis Report (FSAR), Nuclear Quality Assurance Manual (NQAM), Sequoyah Nuc lear Plant Adminis tative Instructions (AIs), Sequoyah Quality Control (QC) Program, Division of Quality Assurance Instructions (DQAls), Office of Engineering Operation Instructions (DE-01s), Engineering, Design, Contruction, and Quality Kssurance Procedures (QAPs), Quality Assurance Audit Reports, and various memoranduins and letters. Also, the Employee Concern Files including the Confidential Files were reviewed for any additional data per taining to this issue. The results of that review indicated two reports (Nuclear Safety Review ' Staff (NSRS) Report and a Generic Concern Task Force (GCTF) Report) had been issued and pertained to this element. These reports were reviewed by QACEG to determine the scope and investigation results. In addition, the evaluation process included discussions with Quality Assurance Auditors, Quality Supervisors, Quality Branch Chief, Section Supervisor - Audit Branch, Past Director of Quality Assurance, Environmental Qualification Project Engineer, Manager of Nuc lear Engineering Employee Conc e rn s , and Manager of Operation Engineering Services regarding the Quality Assurance Program adequacy for SQNP. I
4. REPORT NUMBER 80101-SQN
. ELEMENT TYPE: REVISION NUMBER:
Element Report 5 TITLE: PAGE 4 0F 15 - Quality Assurance Program Adequacy 2.3 Sununary of Findings The issue of " Excessive Paperwork and Procedure s" was sub stantia ted and is addressed in TVA's Nuclear Per formance Plan dated March 19, 1986. The issue of " Procurement Requirements Not Invoked", was substantiated in part (Employee Concern OE-QMS-1) . This conclusion was based upon QACEG's review of documented problem conditions in the TVA Procurement Program at Sequoyah e.g. NSRS Report, Corrective Action Report and t memoranda from the Manager of Nuclear Power. The issue of " Nuclear Quality Aasurance Manual Requirements Not Complied With" was unsubstantiated as the QACEG investigation found no evidence where the Sequoyah site was ignoring their Quality Control i Program or that it did not comply with the intent of the NQAM. The issue of " Management Pressure is Restricting the Audit Funct ions" was unsubstantiated. QACEG investigation indicated auditors were However, no delinquent in closing audit findings in a timely manner. documented evidence was identified to indicate auditors were pressured to close audit findings. ' 2.4 Sununary of Corrective Action The issues "Exces sive Paperwork and Procedure s" and " Procurement ' Requirements not Invoked" were substantiated. Prior to the QACEG evaluation, the Manager of Nuclear Power had assigned the Division of Nuclear Services to prepare corporate level nuclear standards for developing directives and procedures for each of the hepdquarters departments. These standards will be used to 1 evaluate and revise all existing nuclear procedures on a site-by-site ! basis. the issue 5 taken by TVA Management pertaining t to The action
" Procurement Requirements Not Invoked" was to:
- a. Revise the NQAM and Sequoyah Site Standard Practice SQA-45.
1 b. Staff a core of trained procurement groups.
- c. Establish responsibilities for procurement of permanent and sa fety-rela ted spare and replacement parts and to assess those f items installed or in storage for compliance with established requirements.
Management has revised the NQAM and SQA-45, also a core procurement group has been established at SQN. The responsibility for procurement l' has been assigned to the Design Nuclear Engineering (DNE) Division. l , n
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ELEHENT TYPEr'4 80101-SQN Elemer.r Reporti REVISION NUMBER: TITLE: 5 Quality Assurance Program Adequacy PAGE 5 0F 15 They are presently in 'the process . of assessing the material / parts 5 installed or in storage for compliance with the program. 3.0 LIST OF EVALUATORS D. G. Barlow W. E. Bezanson J. J. DeAngelis 4.0 EVALUATION PROCESS 4.1 General Method of Evaluation The evaluation process consisted of researching the Employee Concern Files, including the Confidential Files, Nuclear Safety _ Review Staff Files and the Generic Concern Task Force Files to determine if additional data was available which could be utilized in the investigation of this element. The basic contents of those files were the K-Forms (document used for recording employee concerns),- NSRS + Investigation Report, GCTF Investigation Report, and various memoranda and letters which pertained to the employee concerns and these issues. Reviews were also conducted of the Federal Regulatory Requirements, TVA upper tier documents such as .the Final Safety Analysis Report, Topical Report, Nuclear Quality As'surance Manual, Audit Reports, and Nuclear Performance Plan. In addition, lower tier documents such as site standards, procedures, instruction letters, and memoranda were reviewed to determine requirements, commitments and responsibilities. The revi'eit and evaluation of the above documents and discussions held , with cognizant personnel established the basis for the conclusions reach'ed in this report. , 4.2 Specifics of Evaluation t l 4.2.1 Issue - Excessive Paperwork and Procedures The research' of Employee Concern Files including the Confidential' Files for any additional data pertaining to this issue indicated none was available. TVA's Topical Report TVA-TR75-1A, Revision 8, dated October 12, 1984, and Appendix B to EOCFR50, dated Janaury 20, 1975, specify the requirements for a documented program to be established. The program requires that procedures and s paperwork be generated. l ,I
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k v REPORT NUMBER 80101-SQN ELEMENT TYPE: REVISION NUMBER: Element Report 5 . TITLE: PAGE 6 0F 15 Quality Assurance Program Adequacy TVA's Nuclear Per formance Plan (Report submitted by TVA Management to the Nuclear Regulatory Conunis sion (NRC) which defines TVA's Nuclear recovery program) dated March 1986 was also reviewed as it describes management action on this issue. Personal interviews and discussions were not deemed necessary by QACEG as the Employee Concerns (asnon-speci written) are basically fic as to the employees' opinion and were requirements, programs procedures, documentation or groups involved. 4.2.2- Issue - Procurement Requirements Not Invoked Concern Files, including the Reviewed the Employee Confidential Files, for any additional data pertaining to this issue. 'Ih e results of that review indentified additional information in the form of a NSRS Report ( R-84-17 NPS) and memorandums which were utilized in this evaluation. The following documents we re reviewed for information and requirements pertaining to this issue. Appendix B to 10CFR50, dated January 20, 1975. Nuc lear Quality Assurance Manual (NQAM), Revisions dated August 16, 1985, Decemb er 23, 1985, and June 20, 1986. Sequoyah Nuclear Plant' Standard Practice, SQA-45, " Quality Revisions 16, Control of Material, Parts & Se rvic e s", dated July 9, 1985, 17 dated September 27, 1985, 18 dated November 21, 1985, 19 dated February 13, 1986, 20 dated
... March 4, 1986, and 21 dated June 23, 1986, were reviewed to determine the site procurement requirements.
TVA Quality Assurance & Audit Staff - Audit Report CH-8200-14, dated February 17, 1983, was reviewed as it identified problems in the procurement program. Nuclear Safety Review Staff Report R-84-17 NPS (Attachment C), "Rev iew of Procurement Practices and Procedures for 1985, Operation of Nuclear Power Plants," dated March 12, and the Manager of Nuclear Power response, memorandum L12850520800, dated May 21, 1985, were reviewed as they pertained to procurement practices and procedures. Correc tive Action Report (CAR) SQ-CAR-86-02-006, dated L16860723 I March 10, 1986, and the following memorandums: 855, dated July 23, 1986 and S08 800417 801, dated April ' 11, 1986, were rev iewed to assess the action taken on identified procurement problems. I
k v' REPORT NUMBER: 80101-SQN ELEMENT TYPE: REVISION NUMBER: Element Report 5 TITLE: PAGE 7 0F 15 Quality Assurance Program Adequacy Concern Task Force Report (Attachment B), Generic
" Supplier's Contractors" dated May 16, 1986, was reviewed to assess GCTF's evaluation and conclus ion of Employee Concern IN-86-011-003.
Various memoranda (Attachment D)- pertaining to TVA's procurement program and this issue were also reviewed to determine requirements and commitments. were with the Sequoyah In addition, discussions held Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns, Manager of Operation Engineering Services , and Sec tion Supervisor - Audit Branch for in forma tion pertaining to this issue. 4.2.3 Issue - Nuclear Quality Assurance Manual Requirements Not Complied With were Employee Concern File s , including the Confidential File, reviewed for any additional information relating to this issue. No further infomation was available. Reviewed Sequoyah's Adminis trative Instruction AI-20,
" Inspection Program", Revision 10, dated November 21, 1984 and the site Quality Control Program for compliance with the Nuclear Quality Assurance Program requirements.
Discussions were held with Sequoyah's Quality Engineers and their supervisors pertaining to this issue. 4.2.4 Issue - Management Pressure Is Restricting The Audit
, Function Employee Concern Files and Confidential Files were reviewed for any additional in formation which could be utilized by QACEG in the investigation of this issue. None was available the QACEG pertaining to the issue. As a re sult of investigation those documents listed in Attachment E were reviewed for requirements and conunitments per taining to this issue.
- Lead Discussions were held with nine QA Audit Branch Auditors in order to establish the historical background in formation, pertaining to auditors being pressured to c lose audit findings, the type of pressure applied, and the reason for that presasure.
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L M BEPORT NUMBER $ 80101-SQN ELEMENT TYPE: REVISION NUMBER: Element Report 5 TITLE: PAGE 8 0F 15 Quality Assurance Program Adequacy 5.0 FINDINGS 5.1 Findings on Issues Based on the evaluations and investigations performed by QACEG, one of Requirements No t Invoked) was the four issues (Procurement sub stantiated in part and pertained to Employee Concern OE-QMS-1. Additionally the issue of excessive paperwork and proc edures was sub stantiated. The remaining issues were not substantiated.
'Ihe following addresses both a discussion and conclusion of each issue as identified in Section 1.2 of this report.
5.1.1 Issue - Excessive Paperwork and Procedures Discussion The QACEG investigation identified that TVA had addressed the which is issue of burdensome paperwork and. procedures identified in their " Nuclear Performance Plan" (psges 11, 14, 73, 74, and 75) dated March 1986. That document also identified the root cause for that condition (as noted below) and TVA's commitment to the NRC for resolving that condition:
"In the past, all of TVA departments responsible for nuclear activities have not been unified into a single TVA's nuclear plant s and nuclear organization. -acted have , at times, headquarters departments autonomously, and authority for functional activities was As a re su lt ,
sometimes divided among seve ral groups. lines of authority and responsibility have not always been clear and the implementation of TVA's Nuclear Program has not been consistent." Improvements In Management Systems and controls "Some of involved the problems in TVA's nuc lear program have insufficient programs and procedures, a lack of prior planning and integration of nuclear activitie s , and In a failure to satis fy prior commitments to the NRC. response to these problems , TVA is reviewing its nuc lear procedure s and will be establishing centralized programs and procedures to control all TVA nuclear activities ; TVA has assigned the Division of Nuclear Services with the responsibility." In the short-term, "TVA will prepare interim corporate-level nuclear standards for developing directives and procedures for , each of the headquarters departments reporting to the Manager of Nuclear Power. 'Ihe se standards will be used to evalua te and revise all existing nuclear procedure s on a site-by-site
k J REPORT NUMBER: 80101-SQN ELEMENT TYPE: REVISION NUMBER: Element Report 5 TITLE: PAGE 9 0F 15 Quality Assurance Program Adequacy basis and will serve . as a basis for preparation ' of final Whenever corporate-level nuclear direc tives and procedure s. poss ible, the interim standards will be based upon those provisions of existing procedure s which provide e f fec tive control of activity in question". & In the long-term, "TVA will prepare and is sue Nuclear Powe r Directives, approved by the . Manager of Nuc lear Power, to define the specified objec tives and responsibilities of the headquarters departments reporting to the Manager of Nuc lear Power Direc tives. Corporate-level directives and procedures will be developed or revised for each headquarters department. Plant-specific procedures will then be reviewed and revised on a site-by-site basis to assure their con formance with the requirements in the corporate-level nuc lear directives and procedures". Conclusion of investigation the is sue was As a result QACEG's Based on the above stated improvements, sub stant iated. Services for assigned to the Division of Nuclear implementation, an ECSP - Corrective Action Tracking Document (CATD) was not initiated. The stated improvements when 5 implemented will reduce the number of procedures / paperwork. However, the amount of procedures and paperwork required may still be considered burdensome. ; 5.1.2 Issue - Procurement Requirements Not Invoked
- Discussion and documents were reviewed and i The following reports investigation and reflected the evaluated during this following:
i The Ger.e ric Concern Task Force (GCTF) Report, dated May 16, 1986 (Attachment B) for Sequoyah, stated the concern IN-86-011-003 was not valid. Their conclusion was based on additional data furnished by the Employee Response Team (ERT) which obtained additional information from the concerned individual and clarified the concern as:
" Prior to 1982, TVA Class A bolting material was purchased from Dravo Company. Dravo subcontracted with Texas Bolt for this material. The certified mill test report received from Texas Bolt did not indicate that the material was ASME Class I."
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( v REPORT NUMBER 80101-SQN ELEMENT TYPE: REVISION NUMBER: Element Report 5 TITLE: PAGE 10 0F 15 Quality Assurance Program Adequacy The report also addressed two specific issues: "Does TVA require . material suppliers to have sub-tier suppliers meet the QA requirements for procurement and did Dravo supply bolting material for Sequoyah? The conclusion of the GCTF investigation stated:
"The NQAM, Part III, Section 2.1, does require sub-tier suppliers to meet the same requirements as the contrac t supplier. Also Dravo Corporation and Texas Bolt Company met the requirements for . supplying ASME Code material. Dravo Corporation did not have a con tract to supply material for the Sequoyah Nuc lear Plant."
Based on our review and evaluation, QACEG concurs with the GCTF report conclusion. QACEG's review of the NSRS Report R-84-17-NPS, " Review o f Procurement Practices And Procedures For Operating Nuclear Power Plants", dated March 12, 1985, identified various problems (as noted below) in the TVA Procurement Program which are related to this concern:
" Procurement system is too cumbersome, and no t well known by the users.
There is insu fficient documentation for transferred material. 10 CFR 21 requirements incorrectly linked to Nuclear Power
*- (NUC PR) QA requirements.
Comnercial grade items (QA Level I and 11 designation) were purchased with little or no QA requirements invoked. for No quality verification performed (receipt inspection) commercial grade items." QACEG's review o f Corrective Action Report SQ CAR 86-02-006, dated March 10, 1986, identified the following conditions in part:
" Office of Engineering (OE) is supplying QA material for ASME Section 111 and Class 1E application with insufficient or nonexistent documentation."
"On requisitions for QA Materials, the statement, 'Does 10 CFR Part 21 Notice Apply? yes ( ) no ( )' is being marked out or lined out by OE.
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REPORT NUMBERt ELEMENT TYPE: 80101-SQN REVISION NUMBER: Element Report 5
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Quality Assurance Program Adequacy PAGE 11 0F 15 "Of fice _ of Engineering" (OE) is purchasing "QA" material for Class --1E application as "No - QA" from the vendor and upgrading this ' material to "QA" on a transfer - requisition j from the Power Stores Distribution Center".
" Material descriptions do not adequately describe the item being supplied."
4 The above items were identified as exanples only, and reflect a problem in that the Of fice of Engineering procedural requirements were not in agreement with the NQAM requirements. 4 QACEG reviewed NQAM, Part 111, Section 2.1 "Procuremen t of 4 Materials, Components, Spare Parts, and Services", revisions dated April 1, 1985, December 23, 1985, and June 20, 1986, for requirements pertaining to this issue. The QACEG's review of - the NQAM indicated the later revisions dated December 23, 1985, and June 20, 1986, were revised in part to re flec t organizational changes and reviews to assure procurement requirements are specified in the procurement documents. QACEG's review of Memorandum (R. B. Kelly, Director, Nuclear Quality to W. C. Drotleff, Manager of Engineering) dated July-23, 1986 (L16 860723 855) stated the following in part: ' "As a result of the reorganization, a number of activities which are subject to Part 11 and III of the NQAM are now being performed by DNE personnel. Apparently some of i these personnel are unaware of their responsibility to comply with the NQAM and continue to do business as they have in the past. Please provide for procedure revision and/or training as may be necessary to ensure that DNE coordinate material ,! transfers at Sequoyah Nuclear Plant comply with the NQAM." QACEG 's review of the Sequoyah Site Standard Practice, SQA-45 indicated this document describes the methods and requirements for controlling the procurement of materials, components, j It also establishes and assigns spare parts and services. responsibilities for the preparation, review and approval of procurement documents. The revis ions (dated July 9 and November 21, 1985, and February 13 and June 23, 1986) reviewed indicated SQA-45 was revised in part to re flec t the la te r requirements of the NQAM. Discussions we re held with the Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Conce rn s and Manager of Operation Engineering Services who were cognizant of this issue. They stated action was being I
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REPORT NUMBERt ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER: TITLE: 5 Quality Assurance Program Adequacy PAGE 12 0F 15 taken to resolve the procurement problems, but had no t been fully implemented. Conclusion l The issue of - " Procurement Requirements Not Invoked" is substantiated in part for Employee Concern OE-QMS-1. As a result QACEG issued an ECSP . - Corrective Action Tracking Document (CATD) 80101-SQN-01 (Attachment F). 1 5.1.3 Issue - Nuclear Quality Assurance Manual Requirements Not Complied With Discussion The QACEG investigation found no evidence where the Sequoyah Site had not incorporated the NQAM requirements into their QC Program. QACEG's review of those Correc tive Action Requests (4) and De ficiency Reports (16) issued in 1982-1985, against the Sequoyah's Nuclear Quality Assurance Organization (pertaining to Sequoyah's Quality Control Inspection . Program) found no evidence that the QC organization had failed to incorporate the NQAM requirements into the SQN plant instructions (e.g. AI-20 " Quality Control Inspections", or AI-34 " Training and Qualifications of QC and . Nondestructive Examiniation (NDE) Personnel"). QACEG 's investigation of Sequoyah's Corrective Action and Deficiency Reports (for the life of the plant) with regard to to the ' Quality Control Program, not complying with Nuclear Quality Assurance Manual, found no evidence where deficiencies were written against this issue. Conclusion As a result of this investigation, QACEG found no evidence that the Sequoyah site was ignoring their QC program. The evidence reviewed indicated the NQAM requirements were being implemented in the Sequoyah QC program, the re fore, the concern was unsubstantiated. 5.1.4 Issue - Management Pressure Is Restricting Audit Functions Discussion 1 The concern was considered to be generic for all TVA s it e s , (Browns Ferry (BFN), Watts Bar (WBNP), Sequoyah (SQNP), and Belle fonte (BLN)). QACEG established that a total of 133 o
y . %. REPORT NUMBER: ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER: TITLE: 5 Quality Assurance Program Adequacy PAGE 13 0F 15 audit reports (an audit report could include one (1) or more audit modules) were issued for these sites for 1984 and 1985. Of those 133 reports, QACEG reviewed a sample of 23 reports which were issued during the same time frame that the employee concern was generated. Those 23 audit reports were reviewed for information pertaining to this issue. In addition to the audit reports, the documentation and audit files identified by the individuals during the interviews were also reviewed. The QACEG investigation was per formed in three phases i.e., review of audit reports, interviews with audit personnel and review of related docuinents. The scope of the investigation was limited to the evaluation of two areas:
- a. Were the corrective action methods used in compliance with the requirement s of Appendix B to 10CFR50, Criterion XVIII, " Audits", and NQAM, Part III, Section 5.1 " Audits"?
- b. Was there documented evidence that Division QA Management had applied pressure to the Auditors to close deviations prior to the implementation of comp le ted correc tive action?
Two (2) of the Multi-Site Audit Reports (CH-8500-01 and CH-8400-18) were reviewed specifically because they were re ferred to QACEG by an individual during the inte rview process as containing information to substantiate the concern of pressure being applied to close out audit findings. Based on the review of the twenty-three (23) audit reports, QACEG found that a con.*,derable amount of time was being taken to. close audit deviations. In most cases, a year was average and in other cases, 18 months to 3 years had elapsed before a report of corrective action was verified. Since it was standard prac tice that an auditor who found a deviation was re spons ible to see it through to the veri fication of corrective action, the Quality Audit Branch and auditors would be under pressure to review and verify the corrective action, even though the sites we re delinquent in responding to the audit findings, in a timely manner. From a cursory review of the documentation to support closings of deviations, it was identified that the sites held little regard for the audit deviations found. The Site Directors would either request extensions to reply to the devia tions or ignore the audit reports entirely. From this, one could draw a conclusion that in the period of 1984-1985, the audit program was not being supported by TVA Management. A memorandum from H.G. Parris to Site Directors, in June 1984, made mention that the NRC, on numerous occasions, criticized TVA for a lack of timeliness in responding to audit devia tions and directed them to take a more positive part in responding and closing deviations. s
% O REPORT NUMBER 2 80101-SQN ELEMENT TYPE: REVISION NUMBER:
Element Report 5 TITLE: PAGE 14 0F 15 Quality Assurance Program Adequacy During the rev iew, QACEG found four (4) instances whe re a higher authority for deviations were escalated to reso lution. These e scalations were done in accordance with TVA procedures in effect at that time (DQAI-310, superseded by DQAl-313, superseded by DQAI-104). ' QACEG conducted interviews with nine (9) QA Audit Branch-Lead Auditor s. The results of these inte rviews indicated that implicit pressures were applied by Q. A. management to c lose audit deviations prior to the full satisfaction of the auditor. Conc lus ion While it would appear, based on the interviews conducted, that auditors may have been pressured to c lose deviations be fore they were satisfied that adequate corrective actions had been implemented, QACEG evalua tors were not able to substantiate the concern based on the audits, and correspondence provided and reviewed. The investigator also found correspondence to "All Audit Personnel" where they were instructed in handling
" pressure". (Note: Based on this investigation, the word
" pressure" was used in the context of closing audit deviations in a timely manner as required by applicable procedures.)
There was no objective evidence that pressure had been used or close deviations which were considered implied, to In addition, the review o f the unsatisfactory by the auditor. twenty-three (23) audit reports indicated no "B" evidence of to 10CFR50, violations to the requirements of Appendix Criterion XVIII, " Audits" or the NQAM, Part III, Section 5.1,
" Audits".
correspondence available during the Based on the investigation, it was concluded that the issue of "...QA management pre ssures auditors to c lose dev ia tions. . . " was unsub s tantiated. 5.2 QACEG 's evaluation concluded that two issues " Excessive Paperwork and Invoked" (employee Procedures" and Procurement Requirements not MRS-85-001, and OE-QMS-1) were concerns BFM-86-002-001 and sub s tan t iated. The evaluation of concerns Bnt-85-002-001 and MRS 001 indicated the TVA program in e f fec t did propagate exces sive procedures which resulted in excessive paperwork. The evaluation of Powe r concern OE-QMS-1 indicated the Power Stores / Nuclear Plant Operations procurement s process (NQAM) did not assure applicab etc.) we re le requirements ( regula to ry , design base, quali fic ations , being met. These issues are being evaluated by the Manager of Nuclear Power to dete rmine required correc tive actions and any potential we re The remaining employee concerns impact to sa fe ty. sa fe ty-unsub st antiated and even though designated potentially l 1
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ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER: 5 TITLE: Quality Assurance Program Adequacy PAGE 15 OF 15 significant or sa fe ty-rela ted in Attachment A, they were not considered detrimental to the safe or reliable operation of the Sequoyah Nuclear Plant. 5.3 Correc tive Action TVA Management has taken the following corrective action on the issue 5
" Procurement Requirements Not Invoked".
The NQAM and Sequoyah Site Standard Practice SQA-45, " Quality Control of Material, Parts, and Se rvic es", were revised in part to re f lect changes required to improve the TVA Procurement Program. Also, the Design Nuclear Engineering (DNE) Division has been assigned the responsibility fort
- a. Procurement of all spare and replacement parts and materials for permanent and safety-related equipment.
- b. Establish a Staff core of trained procurement groups at each site by June 30, 1986, to prepare, rev iew, and approve procurement documents and assure compliance with the NQAM requirements.
The above improvements are still being implemented by TVA Management. Based on the QACEG review of available documentation it could not be substantiated what action was being taken on equipment, components, mate ria l, spare or replacement parts already installed or in storage. As a result, Employee Concern Special Program (ECSP) Corrective Action Tracking Document (CATD) 80101-SQN-01, (Attachment F) was issued. The SQN Site Director's response dated January 6, 1987 (Attachment G) to CATD. 80101-SQN-01 stated a Replac ement items Task Force had been assigned on November 17, 1986. The primary function of the Task Force is to develop measure s to control fu ture procurement, is suance of items currently in Power Stores, and to verify acceptability of installed items. These actions are presently being implemented by the Task Force. Implementation of those actions will be verified at a later date. 6.0 ATTACINENTS A. Listing of Employee Concern Information Subcategory 80101-SQN. B. Generic Concern Report - Suppliers Subcontractors, dated 5/9/86 C. NSRS Report R-84-17-NPS D. Documents Applicable to IN-86-011-003 and OE-QMS-1 E. Documents applicable to XX-85-116-008 F. ECSP Corrective Action Tracking Document 80101-SQN-01 G. SQN Site Director's response to ECSP Correc tive Action Tracking Document 80101-SQN-01 dated January 6,1987. I
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i ATTACIINENT A PAGE - 65 TEHHESSEE VAI L EY AUTil0RITY RUll llHE - 14:29:59 4
- ECPS120J-ECPS121C .0FFICE OF HUCLEAR PDHER ' . RUll DALE - 01/21/87 Rf f ERtilCE 1' IRLQuti!CY - REQUEST EMPLOYEE COHCERil PROGRAH SYSTEM (ECPS) unP - 1555 - Ritti EMPLOYEE CollCERh IllFORHATIGH BY CATEGORY / SUBCATEGORY fl0llCONFORMANCE REPORIlllG/PROBLEH REPORTINO t
- SUSCAIEGORY
- 80801 '
;AIEGORYe QA QA/QC PROGRANS ?
5 1 REPORT APPL H 2 SAF RELATED CollCERil 4 S FIllo CL ASS HISTORICAL CONCERN DESCRIPTIoll -- SUS R PLT REPORT ORIGIH --
~-
f CAT CAT D L OC BF BL SQ las - ------ -- - .. CollCERif IIUHBER - - -- -- ( l --- ----- - ---
; -_---- - -- ---- QIC IH Tile PROCESS OF EMPHASIZIRO Tile IMPORTANCE OF 'Q QA 80101 5 BFH IN N Y N UALITY" TVA HAS INTERPREIED "QUAHIITV" AS Tile HEAll BFM-86-002-00101 2 HA IIA 180 llA IHG, E.O., EXCESSIVE AHOUlti 0F PAPERHORK Allu PROCE T t
150246 S HA IIA C llA DURES. 1HE PROFESSI0tlAL CAN REDUCE AllD SillPLIFY i 02 QA 80109 5 BFN 1Y H H Y HE PAPERil0RK AHD PROCEDURES HITHOUT REDUCIllo " QUAL ITY". HUCLEAR'.P0HER CONCERN. Cl HAS 180 FURillER I 2 H0 144 IIA 140 3 .NA HA HFORMATIOll. . QTC TVA DOES NOT REQUIRE HATERIAL( DET SUPPLIERS AIL S TO INVOL 1 il N Y H QA REQUIREMEHIS Dil SUB-TIER Ill -Q6-011-00 501 QA 80101 5 Hell 2 HA HA SR 144 KH0lHI TO QIC, UNIT 1 & 2.SUPPllERS.HITilllELD Cl llA I 150188 3 HA HA E 11 4 ). CONS 1RUCil0N DEPT CollCERN. l 02 QA 30104 5 HSH IY Y H Y S l10 ADDITI0llAL INFORMATION. i 2 SR SR llA SR 3 ilA , i 4 OECP THE AHOUNT OF PROCEDURES AND PAPERHORK HAVE BEcollE', O!
- QA 44101 $ SQN 1N H Y H Tile PRIMARY PRIllCIPLE OF CONCERil AT SEQUOYAH Tile ALTITUDE OF HAllY AHH , .
?- HRS-85-001 2 114 IIA IIA IIA NOT THE QUALIIY OF THE HORK.
] 3 144 HA C HA PEOPLE IS THAT IF QA APPROVES IT, THEN THAT IS GO QA 80109 $ SQH IY Y N Y OD EHOUGH. I THEREFORE CONCLUDE THAT THE SAFE OPE O2
; 2 HO N0 11A HO RATOR OF 1HE PL ANT IS OVERSHADOHED BY THE AHOUlti 0 3 HA F PROCEDURES AllD PAPERHORK TO BE DollE.
l a i OECP THE PROCUREMENT OF NUCLEAR PLANT SAFETY SYSTEHS, RELATED E HA / IN Y H 1ERIAL, COHl'OllENTS, DEVICES, EQUIPHElli. 1 OE-QHS-1 01 QA 40lRI $ NPS 2 IIA IIA $5 llA IC. BY THE P0llER STORES /HUCLEAR PLAlli PONER DOES aloi OPERAT N-
- 3 HA HA E ilA 10815 PROCESS (HQAM PART III, SECTIOli 2.1)
! 1Y Y ll Y ASSURE THAT APPLICABLE REGUL ATORY REQUIREMEllis, D i i 02 QA 80104 5 HPS 2 SS SS IIA SS ESIGH SASES, QUALIFICAT10llS AHD OlllER REQUIREMElliS
- 3 HA ARE BElllG HET.
ARE IGil0 RING THE QC P l QTC TVA HUCLEAR PLANTS (GENERIC) TifE IIBM-86-004-00201 QA 80101 S HPS 1H H Y H ROGRAM FROH IHE NUCLEAR P001ER OFFICE (HQAHl. 150259 2 HA HA 55 llA PLANTS ORITE THEIR DINI PROGRAMS. AllD DO llei F0ttull
- S HA HA A IIA INSIRUCT10145 FROM THE HQAN. 100 FURillER INFORNArt
- 02 44 40109 3 HPS IY Y ll Y OH AVAILAttE IN FILE. AHONYHOUS C0llCERil. NO FOLL j -- 2 SS 55 18A SS Dil-UP REQUIRED.
3 flA _ QTC DIVISION OF QUALITY ASSURANCE HAllAGENEllT PRESSURES AUDIIORS TO CLOSE AUDIT DEVI ATIONS (SEquotAll) BEF XX 116-00801 QA 80101 S SQN IN N Y H 2 Ita 114 SS IIA ORE IllE AUDl10R IS SATISFIED THAT ADEQUAIE CURRECT 1502il . 3 114 llA A IIA IVE ACT10H, AS ST ATED IN APPENDIX B Allo IllE QA flAll 02 QA 80114 5 SQH IY Y H Y UAL, HAS BEEH IMPLEMEHIED. DETAILS KH0lill TO QIC, 2 SS SS tlA SS NO FURTHER Ilif0R S HA HITHHELD MAIIUll MAY BE DUE TO CONFIDENTI All1Y.CI REQUESTS TilAt QIC Pl. RELEASED, ; ORM THIS INVESTIGATIoH. . MUCLEAR F0HER DEPARTHLili
-- CollCERN . s i
6 - ._..... ....,
.)
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* ' 'AT'TACHMENT B R2 vision 1
~
. . . . TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANI GENERIC CONCERN TASK FORCE
- GCIF i
Employee Concern Number: IN-86-011-003
/ ,,
Subject:
Supplier's Subcontractors I Date of
' Investigation: May 9, 1986 1
< s i% 10,F% Investigator: 6M
,}J.E.Engelhardt f % ste
' 'yff /0 /fOk /
/
t Reviewed By: UW , (/Date GCIF Member
% -~ # _ _
6 ~Ibbb Approved By: Date
.W.R.Lage(gren 77 y.' f i
W 'Date i MRG, Member
}i .
Date l
.:.@ WBECIG l
- 00047 1.
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, Revision 1 ) 0.t,* .
I. Dackground An investigation was conducteil 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 PJant ( WD N )' . , 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,QTC and identified as IN-86-Oll-003,. stated: TVA does not require material suppliers to involve QA requirements on sub-tier suppliers. The f1Llollowup group was contacted to receive furthur 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 wcs purchased from Dravo Company. Dravo subcontracted with Texas Bolt Company for "this material. The certified mill test report received from Texas Dolt Company did not indicate that the material was ASME Class I. No further information was requested from the ERT followup group. II. Scope A. The scope of this investigation was determined from this concern to be two specific issues: ,
- 1. Does TVA require material suppliers to have sub-tier suppliers meet the QA requirements for procurement?
- 2. D,1,d Dravo supply bolting material for seguoyah?
B. To accomplish the investigation, Nuclear Quality' Assurance Manual (NQAH) requirements were reviewed and the Procurement Quality Assurance Branch, Supplier Evaluation Group (PQAB SEG) was contacted. III. Summary of Findings A. HQAH, Part III, Section 2.1, " Procurement of Heterials, Components, Spare Parts, and Services," list the requirements for procurement ! of QA material. This NQAH incorporates the following requirements: '
- 1. ANSI 45.2.13, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" Page 1 of 3 L - - -.- - - - - - - . -- ._
i, O g .
- f. ,. . [r.. . .. .
P , Revisien 1
~
- 2. ; Regulatory Guide 1.123, " Quality Assurance Reguirements for
' Control of Procurement of Items and Services for Nuclear Power Plants" *
- 3. ASME, Section III, art,1cle NCA-3800, " Metallic !!aterini Manufacturer's and Material Supplier'r Quality System Program" '
- 4. Other applicable standards These standards require that sub-tier ^ suppliers also meet the same QA requirements as the supplier.
B. ' Supervisor of Sispplier Evaluation Group was contacted about the implementation of NQAM, Part III, Section 2.1 and DravoQA's Supplier Corporation's compliance with these requirements. Evaluation Group audits suppliers of QA materials to TVA's nuclear
, plants.
Part of this audit process is to verify that suppliers i liers
, , , maintain a QA program that will assure that any sub-t er suppDravo Corpor also meet these requirements.
certificate which certifies that it meets the QA requirements Texas Bolt for It was
,. supplying ASME code material for nuclear plants. Compan audited by PQAB SEG in October 1985 (aucit 86V-14),
Both Dravo Corporation and Texas Bolt Company problems were found.
' are on IVA's " Acceptable Suppliers List" for supplying A material.
- to WBN.
IV. Conclusions and Recommendations A. Conclusions The employee concern was found not to be valid f(r the f allc, wing reasons : .
- 1. NQAM, Part III, Section 2.1 does require sub-tier suppliers to m6et the same requirements as the contract supplier thich is verified by PQAB SEG.
- 2. Dravo Corporation and Texas Bolt Company meet the requirements for supplying ASME code material.
- 3. Dravo Corporation did not have a contract to supply material for Seguoyah Nuclear Plant.
B. Recommendations.
- None ,
I Page 2 of 3 e
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Revision 1 Q V. References ' ANSI N45.2.13-1976, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plant" ASilE Boiler and Pressure Vessel Code, Section III, Articles NCA-3800, *
"lietallie Material Manuf acturer's and flaterial Supplier's Quality System
. Program." 1983 NQAM, Part III, Section 2.1 " Procurement of Haterials, Component, Spare 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, dated October 17, 1986 and November 18, 1985, RIt!S numbers L19 860117 802 and L19 851118 800 respectively .
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UFPer-Tier Documents Plants. ......................... 12
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.' 4.c Ip.cl~. ...t c ; 1. Preparation and Review Cycle for Procurements. ... 12 f
3 T' 9 - ' a. Originator . . . . . ............. 12 M' 1 T.h,h}?th,,)
)f-l*, * ,b. Specifications Engineer . . . . . . . . .... 13 .,
,, c. Field Quality Engineering . . . . . . . .... 15 . -;
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d .' e. Plant Superintendent. ........... . . Power Storas. . . . . ............. 16 - f.' 2.'l Functioning of F? sot Procurement System. . . .... 17 d
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4..l ~3 : . 2. Power Stores Dis tribution Center '. . . . . . . . . .. .31 :: , t,( ! 32l'/};1[$*f' l[lf j T. .3. Central Office. . . . . .. . . . . . . . . . . . . . .
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% e: PrAleen essociated with 'the '. 3 .. timely receipts of procured natarisis.Vf.d.; .4 6 I h ' f; A ' ,; 1.,' hiew been the subject of the Division of Mucle a r Powe r (NUC FR) disa..- d e4 q .g -
- ? ' Minsestees om momerous occasions, and as a result of the Regulatory re, S.*yyI3 '
Ne "E liPerformance lep rovement Pro g ree (RPIP) at Browns Terry Nuclear Plant M Jg.h % l$~i ,' ,'( (EFE), E33t3 aug pert ves solicited in the form of a review. Tbs review M.'. 2 l- '; '. .' ; wee cemeected to easeine and evaluate the procurement process for m . :q l 4'
. anclear plaats and determine the reasons for time delays and problema. ,u f PYg
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- 11. SCDt1 The procurement activities associated with TVA's nuclear power progree .
t were divided into two phases, operating plants and plante under con- .. { striction. This review covered only the operating plants and centered . y1
- 5. ee atuality level I and 11 items and s e rvi c e s . Those s e rvice s or l
items manuf actured by TVA we re reviewed for only BTN. ; As a part of the NUC FR reuraanization ef fort to seve personnel free
- the Nuclear Fower Central Office (NCO) and to solve procurement prob-le=s identified by a joint Division of Purchasing ( M CH), NUC FR and ,
Power Stores ta s k force, NCO procurement activities were transferred to the sites. Interorganizational communications and working rela- ,
, tionabips were stated to have been developed to attack probleme and streamline operations. NSRS did not include the evaluation of the t
Y4 reorganization within this review, but did eva lua te the ta s k force findings based upon the findings of this review. Ill. MARACEMDrT Sut1ARY During the past several months NSRS has been reviewing the procurement process of materials and services for TVA's operating nuclear plants. The review began on June 11, 1981., and continued until the final cle. cost in Chattanoons on December 5,1984 As a part of the review, g closeemts were held at the coapletion of the onsite review at BTN, SQE, ECD, and Fi!RCJI. Throughout this review, people within NUC TR, power Stores, ITROi, and the Office of Engineering (OE) were ve ry belpful, cooperative, and in many cases candid. Virtually everyone i nte rvi ewed coe s i d e r e d_ p r o c u r eme n t to be a _. nsht._ p roblem, and to a Imrge extent Jbgeles was the "o t h,e r.. z ul" Interviews were con-docted with a'aumber o!Tdica ted people trying hard to do their job ,, , 4 ', se they saw it, but f rustrated hqape_the system a gulationsuQA 3 , G s figwere_ perceived _tOtverking against tbcq Each group within .
)l the precurenwst chain had real probicas and had several examples they q l sers willist te share, f y _ g lamo erperienced tLEUC_Wngrocuring mate rial _s in a timely -7 susimsd r fe N~le r ikJoes LJ a rt problems created byg 17.
In broad ;-} gasess, thers were five catsgeries within trkich identified deficiencies - eseu be placed. O i V
- g. pres ral De f **148 titr Wi th Prece reseet cycle ,
Pervsammel seeeciated alth enk ster of the preewremest cytle veri
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(tj e ' thety re,peestbLlityl bewver, aware of the h n M i t es," o r probleet_gt e{Jh(werei setwitECihCPlecurementf*q Py . y(' .' h',I (M[f /M ".P et) c ' ' , lX - ta bers g Ttbknew*.llej_ _ thewet _fEnfer systee.theUnrealistic more than to peoplewere inteRievedsfdf.',Rr j; g.
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yg.- . '. , ..-j.M**)la~cei~ epee the p roc urement systee by originators of procure [ 'N C . di ,O'; Q . meets withia 90 ' Orested days wthen, esterial was reque s t ed to be onsite ,;% [' qgenerally - We.,, g , li ' ' based upon this review o f p ro cu reme n t s , - 6 ._ M "/i'-4 N
;meethe to 1 year would be more realistic. No one knew bow long .sp N ' %
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,,4 . 3 . d T it would take toj archase materials but it was_geBerally accepted
' % f Uhey would noI % there when needed.
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. , r-y .- That lack of knowledge o f _ the._rtccurteent system and associated ., ..$;
{problema p roduc ed frustration along the p r o c u tt m eAL_Eb a in..___A L_,, the e f teFIM p ro c u r e me n t cycle and regulations were viewed at .,; al % 2Izational leveI M Ia burd A an U hhisped U make de~ , .. ) i urescot process more dIIIIE1E The system a n'd reguli @ ns~ "T [ @ern31} w Wd as scac51ocks leriche sites _why_ _tTieJ T6uld}ot'
' .T
~p u r c ha s e siomething versus bow to p~urchase sonctbing and were l alsodesigned to purchase seeething llow bid)7 be site did not 6
went over what it did want. As a result, the sites were putting more effort into using the system shortcuts through the overuse [f ?
. of emergency purchases and field purchases rather than learning L j
. the system for normal procurements and how to work within it.
.;:. s G .' , "
There was no p ro cu resien t training identified at the s i te s for
" persehnel within the procurement cycle. For the most part per-sonnel were introduced to the rigors of procurement by being
, handed a copy of the site procuressent procedure (e.g., SQA 45), ,
, which was over 300 pages long, and told to read it. They rocure,- a mani o f ' i t em s appeared to be viewed _ by site personnel . as a required _ undesirable job as if it were part of an initiation. /
R. Excessive and/or Ineffective Review of Purchase Requests and j Requisitions 3 Typically 17 yproval signatures and initials, some by the same people required to sign both the purchase request and purchase fE l requisition, were required for a site-originated procurement. The value added to those documents beyond what the originator, f
- quality assurance, and authorizing of ficial contributed was, for -
the most pa rt , minimal. In a very small number of procurements tha t w re censidered more complicated, the NCO provided valuable I ispot. Considering the timeframe to prepare, approve, and trans- ,-
, l l mit a procurement requisition free the sites to vendors for bids, " d the sitse typically took one to four days, FURCH about three
- days, and the NCD weks to months. The value added by the NCO, j which was primarily editorial in nature, could not support the i contimmed time delay by the NCO in the procurement cycle; conse- ,;I' geretly, the removal o f the NCO f ree the review cycle and trans- '. I f ar ei the e f fected PCO pe rseenal to the s ite s wa s viewed by N513 j ee a pee t t in eet t ee prwvided the NCO probleme and delays wre )y .,
set trame serted with thee. -
^
1 3 I
. . .[ '.
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( m. v.f.hf / 'f(bQ.y,df " I.Mi,'.1 - . hkN [ S.
.k)rita ,veeteus, wee pre 41ested the concept of safety in spee.h typested tomuse Mt that
,j
* - the ' 3' yh; i
yestire r
, j lj r procureeest i
( systee, w l .' idbeet,'1.e. the more people intelved in reviewing, the better the . .gg f peeemet. t eeteelity what it&RS found was procurement doctamente r 4.Mc l
. helag ehemmed for no apparent good reason other than a perceived , . g iPl ;
S. mood to emenestrate a esgree of usef ulness by each successive 7 +M j
' ' *f. *.*.
<h{.f( G ' .
h -. All pe+curseesta generated by the sites, both QA and non-QA, were .,',, j r=11ewed by the site Field Quality Engineering Group (TQE). For '% 1 the meet part there was one individual perf orming that review at .. . ,; l each sita. .These procurements included direct c ha r g e s , IQTs, .', . field parthases, transfers, and Material Management System (MAMS) I resc4ers. . For example, at ETH during May and June 1984 there 1 were 1051 procuement actions or about 26 procurements per day c ;g that revoice4 TQE review and approval. The effectiveness of the I review on that number of procurements by one individual is ques- ; _ tiesable, and the ef f ectiveness of the review of QA procurements $ , could be enhanced if the review of non-QA procurements by TQE werv performed only on a sampling basis. _ C. Imeffettive Use of Available Procurceent Systems
~
j IQT contracts are surposed to be time severs in that once the IQT u has been reviewed and approved. Requests for Delive ry SDs)
. assinat the IQT can be issued directly to the vendor without the review and approval process required for new procurements. j 9)4 3DC PR's procurement procedures negated any tine savings af forded i by as IQT becson they required the review and approval of each l RD as if it were a new procurement. There was no mechanism to .
l' yd identify large use items, such as steel, as potential candidates @ for IQT contracts. . HA*.t5 is a computerized systes to maintain an established supply l ef inventoried stock items throughout Fower, and has the poten- n j - tim! ef being a very powerf ul tool. The maximum inventory level p, ii g med adalous reerder peint for some staterials were inadequate, and 3 I the sites established the practice of hoarding items such as spops i l (i and plastic bottles to coepensate. The sites viewed the estab- jff ,l l 11shed moniamm/ minimum levels as arbitrary and an effort to r 3
' l l
( avdece stech inventories. In actuality the established maximum / - ,- = sotaksan levels were melther, and the site problems can be attrib- Q ,. uted to peer ccesamication between the site and the Materials . b j n Services Staf f (!?tSS), who administered MAMS. ;! k
- Altbeech f9W5 bed the capability of reordering QA itees autoesti- M E l[i es!!y, eines fait 14ted by Power Stores, this espability could not $
be stilised one te the reerder prescan not being approved as a QA , y systen. As such , essetherised ch ease a te Marts inf oruatIce ce - y ,. , I spedi84s4 Lees , etc., could etenr. Thereiore, eiferta we re
^
_, te orita e 04 presrse f er IWt1. Ia additice, tWC3 had - the espeN 13 cy e( camel steg 1 t he e r de r e i roe di f i e rent s i t ea f e r eme-94 asterta!, bot secerdiet t* PetSS peeseene1 wee etastraimed ;
- g 97 Sth e( the Somers! Caenes1 (OM) reteirsometa sed thet it .. qg ,
...u .e I
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,..he,;gh,( ~ : 1, . coold .es be used. Hans w.. al.e 41. advantaged by .et havies a ~
13 l
,f '
eseplete usage history of inventory items. Investory items c* eld E- ,' . be espiplemested by field p u r c *ia s e s and direct charge rutchases U l b., ' :.f[D J),, ,0. h.4h*I
.I,'$'. ,' i eith n .'seve2.r be' c esse a p a r t o f a u s a g e h i s t o ry . l h i- .h O;.f. '
' '.'2, .
D. Arteront Lack of Plannig
$,h;
.t . . . i .* :, c.f . '
Ir323 did not s pe cifically look at work planning and its asso- i -
) 'j[bhc'f b h'.I cisted impact upon the procurement procese during ti,e review. It b f,4 , f.: ;M 4 'u. , ,' was covere 1 in en NSRS review of outage controls (see 3:33 Report .
l M:t:( l! C ' . ' R-84-27-SQ4/BTN). It was evident, bo=,e v e r , from the conspievous absence of the discuselon of a planning or scheduling phase i f K. .!. J'.'; 6 'l during inte rvie ws that whatever work planning was occurring, it '. l i , , had little positive effect upon procurement. That ob s e rva tion was supported by the identified fact that engineers at the plants
]
,,',*,'f
,;', l, , were scheduling modifications without having the needed material
.]** , . onsite, with unrealistic expectations on delivery dates, and were 7 _; '. . , . using a large number of emergency purchases. Engineers were
.Wb.
. relying uron their ability to find the needed material scoewhere
' 'N *
- 7 within the TVA system when ordered material had not arrived ff..], onsite. The review did not attempt to determine bow many jobs b . ,, required cancellation or rescheduling due to material abortages.
32 ,
.. f Contributing to the problem of planning work was the f act that no
.* . . . , } one inte rv iewed really knew bowjongdt _took_ to procure _An itew 'O
{ f,$ 'J ~I t le understood b7NSTLS that there is no one timeirame app 11= f U ,.',d 3 ;f .' .' cable to all items procured. Examples were found by and identi-g,G' . ,bi fled to NSRS of profu_rementsjhalgan,gelf rom a few days to_pJet
.tbree years and still waitio2 A reasonable estimate should be h,; y ,,
estabIlsbed for routI I rrocurements based upon past procure- , f mente, be it six months or.one year, for use in planning and ,J 37' gj. ; . '
*. echeduling,
, 'D,!
.p -
/
E. I
! Quality Assurance p q.
h i
. , . The quality requirements for items procured was a portion of this review. The Operational Quality Assurance Manual (00AM) _ w a s y/ '
reviewed with regard to procurement and f oundjoCbc_ta t,11F .- and__ con flictingjn eone cases. The main psoblems j ',, cunt le r s oec l g.,'
" Identified were the interning. ling of 10CTPJ art 21 requirements wi t h__q ua l i t y eseurance require cats and the use of cremame r cia l g.
8f.84f.Atese as besic coeponents. t '_ _ I 1
' ,' The qualit y level I and__Il designation _le used for basin snecg- 7 ]
j* meets a nd___10C F R21 appiicabalgas d e t e rm inWlo t,ALLprocurs-meets with t ho se,,q(lev.e LJe s una t ion s . In the determination of
> f rart an arriscability. rart 21 cooli V deter =ined not arritcable 1 *. 1 becesse Ll.e item being procured was a commercial grade ites. If ;
j it were . comune rc i a l grade ites then the quality retuirements .lh a "' ' j . teeid be significes".ly s educed le ellow the precureeest free eas i Jt usepp r e,w weeder med receipt taspectioe by na taspector met I . g.stified te AJrs t 545.2.6. The OQAN, Part 111, Sectice 2.1 [, Aryendia I, fers f o r de t e ris t a lag Part 21 eypticability weg eet1. , eteet end wee be t a< ma s H l a t ha t i f == t tee we e 16cet t f ie4 ee I c,. sessmen tal gsede .e dete r=1*at1** **e refaired et its e t teet c , I
ib. 3 [a ,N - t) t n-,. a. l l; .,3.,Q,5df.fsWL VQ ~ ' i
, q
, bE7f*',y
*. Q,a
&;2 . - C i L ',?'G. * * ' : . ~
~
\ ~9r.QaO; I kW. the safety function el e C85C co*posant er system. Naay 04 level WEp ,p' '.l' I and II, Fort 21 II/ A, precurements of coemercial grade items i
- [jh. d ' ;.' trere seen. All procurements, however, in the QA level I catsgery Ter h.l WS '. ~ rnwired TYA approved vendors and quality doc tame n ta tioe .
*R' those wit.h a QA level II desigestion, which is almost equall; 5,
. h,;j. ,
- T important from a safety standpoint as a QA level I itee, mo8t l
p f C..*' requi red no QA documentation. Frocurement with a QA level designation and no QA documentation or manuf acturing requiremente 7., M g:;, -
' results in en implied level of q ua li ty that just may not be ' - i 3 !*c e there; also, it results in purchased equipment whose quality (
I,.. ,- characteristica are not known. l A b,' J
$ ', , The use of coarsercial grade items as basic components le allowed
, ._: t by the FRC. In using such an iten as a basic component TVA
',,.- assumes the sole responsibility of assuring that that ites will
- b. . . ... Perform as required when required, including an accident situa.
Qi, ' tion. Currently TVA has no receipt inspection progree for com-
' p'.
me rcial grade items that includes testing or s eeie o the r me cha n- I ism, such as vendor audit, that can aske that assurance.
- f..W.
, [*
- Considering the five basic categories of problems enumerated above and g i ;g,, " other findings identified elsewhere within this report, a c repa ris on g
lr 7,~ ' r was made with the findings of the NUC FR Procurement Froblems Task 3 Torce Report. Vith regard to the work of the task forte and their
= findings, NSRS believes it represents a good work effort. Based upon d.,* , .
the findings of this review, NSRS can support many of their recommen-
,, .;. .j : dations that are directed toward changing the system, such as:
1, I. ,4T
'f ..
- Establish a planning group -
j :P
- leprove FURCH/ site comunications i Eliminate unnecessary procurement cycle steps i I b < -
- Better utilize automated systems
,'..t',,
; ./.
, ' NSRS understooil that many of these recommendations were being isyle.
mented, but did not review the extent of the implementation. Other k'15 ' task force recourendation,., however, appeared to be dir e c ted _1cnr a r d 7 Tho7Tettl M be system as as or developinQ ability [Lla_c.e,hlami G witI F the present system with whic D $RS does nol~igiee. 3 , In the details of this report additional problems are identified in (l 4 I the areas of approving vendor s e rv i c e s , documentation inadequacies with internal TVA trans fers, TVA f abricated equipment, receipt inspee.
, tioe program, and materials with a limited shelf life. As negative es the findings may be MS_RS,wants to emphastae that the fy(gg g,gg rag t, I
for the most pa rt feoplef ro,blems b _ but are stre probless. Feople,dp l p A kav,e y _ procedures or train g _to per o.= the task note gig - s (I M k
$ As Ests soggested soluttoa to the problems found duttaa this reviev is 1
coecaimed la Attachment 1. tei
*s
[l ;; l }{. }- f.'. s.}', [._ l w;-of7,nvv f .}-l. ..
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p : M ln M( ' . y.... ai
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f,.'Af:$,.r- ., IT. NH'10EIS AND RICort1ERDAfl0M8 l . A. R-84-17 NFS-01, The Procurement Systes is Too Cumbersees and Not Wil Known by t he U s e r s - i {';h., 3 *
$l.?eN ; ' - Coselusion
,p .
The biggest problem f ound with the procurement system itsed try IrUC 2
#l3,.4,;
;']M ','. PR was its wasteful and cumbersome nature. Procurements we re ' '
,' ,(
overloaded with redundant reviews producing little value added in most cases sad causing unnecessary time delays up to months.
** . Virtually anyone could initiate a procurement action with little
.t,'
or no training. No one was found in the procurement process that .
/ - knew the process such beyond their sphere of involvement. That
? 7-resulted in unrealistic espectations being placed upon the systes by the originator with regard to delivery time, and in perpetua=
,'s.," tion by others in the process who did not correct the problems or e '*
expectations. One of the more cumbersome and redundant review processes occurred within the bCO, and the removal of that review g/.
' . ' process on October 1, 1984, witt the transfer of people to the sites, will help streamline the process provided the Central Office problems were not also transferred to the sites. do
' correct the problems with the s drastic intro s pe c tiv e
^
) E gement analisir 3rTECToni aic~ystem,ie'va i t red (s e e seclIoE V.ET
('. t,j . .
~
~~
l , , I m 2;-3, ~;4bi'V~.D[aAU~ii) .
~
V;'. E Re coenend a t ion s
$.i W~
- y{
t R-84-17-NPS 01A . ; Ibe Frocurement Problem Task Force r e c oamend a ti on to eliminate t all unnecessary steps in the procurement cycle with the goal of y -
' f. '* fk
, , k fd Nplacing very few, if any, steps between the requisitioner and the g
purchasing agent should be given the bigbest priority. c.,,' , R 84-17-NPS-OlR A formalized, documented training program covering the entire
' procurement process should be developed and required for all
*, , personnel within the procurement cycle from the originator
; (h * * (requisitioner) through the purchasing agent.
i' l R-84-17-NPS 01C l A realistic time f raer(s) should be est ablished for routine non-special order procure eente, beoed upon past esperience, to cover , the time required f rore procurement origination through receipt of { the materiel onsite. A mechanism sliould be included in the 1 p procurement system to periodically tvaluate and adjust that t timeframe se neccesary, as well as coemunicate the timef rame to levolved personnel (planners, procurere, etc.). ] I 3 84-17 urs 01D (
', - tie t e r ia l a v a ifebilit y and procure *ent timeframe. skuld be in-c liee d is all malatenance and modific at1** planssing activittee.
imn, me ren e.d.ii.e i. predie.ted % 1.f o r.e tt.s tut j
-he. pgx r1 l e devo l er ing a ene i s t e ssac e and modific. ties plom teg, e d ,
l f$'; .hffff5. l
- f. -. . . . 1,\ &:f.' 1. lki f .': Q i...}. y f x y p .f-Qf,;..[
k'CQ .";'.ht'f 7.f.O . * . L. * ': . . m' s.: .' j ',,,: g. %., a:- q' - c.\ ..s : s
.h.v Also see NBAS Esport 3-4-27' Fi.$ . ,;.[. .' . E ochedeltog inacties at eeth ette.
S@/STE os estege control.) M ...f.$ . ' -
- v. , g. , , SQll_
3' R. R-M =lf-NPS-02, I.a c k o f Ap p r ov a l o f On s i t e Ve nd e r Se rv i c e s a t f.f.'Y- ' ' Conclusion
.f.V
,', I The OQAM, Fort 111, Section 2.1, paragraph 10 requires and iden-
- tifies three acceptable methods f or evaluating and accepting the J$. work performed onsite by vendors. Contrary to that requircoent SQN received services on three separate ocessions and could not
.' p rov id e , after repeated requests, objective evidence that the
', ' s e rvice had been evaluated and accepted in accordance with the OQAM requirement. It is therefore concluded that OQAM, Part III, Section 2.1, paragraph 10 is not being implemented at SQN. (See section V.B.4.a.)
R e ccesse nd a t i o n
}. ,
' e SQN should develop and teptement .e piogram that satisfies the requirement and intent of OQAM, Fait 111. Section 2.1, paragraph 9 10.
h p '(.; C. R-84-17-NFS-03, Excessive Review of Requests for Delivertes (RDal
! 1 on IQT Contracts Conclusion
. . WC FR was reviewing and apprisving RDs with the same rigor as the ~
IQT contr act , against which the RDs were written. That consti-
' ,tuted a redundant effort costing 20 days or more delay in receipt
'.' of the coanodity or service. (See section V.B.4.b.)
. E Recoenendation 3
WC FR should streamline its procedure for the review and arprov-al of RDs, with no (hange of contract involved, to be in line with the requirements of the *fVA Procurement Manual. D. R 84-17-NPS 04, Insuf f icient ilocuinenta t ion f or Transferred Material Conclusion ID-QAP 4.3 requi res the original contract to be reviewed by the site receiving the transferred material for technical and QA requirements. No objective evidence could 1,e fcund substantist. 1 tog c ompl i a nc e . Sitee requesting material to be transferred to theus try asether TVA or ganisatton or location did t>ot specifically feestify d oc ume n t a t t ee requirements or require a copy of the Th re f o r e ,
! erigsmal centract time mate rial wa s pur cha sed ua6e r.
t he seretelag site had a limited basis for accepting material h dartaq t u retelpt l a s po r t t ee p r oc e s e . The site assumed that all rs. 8
l ,S *C
. ). sE,0.M*Q/[fY.'2"
. ,..w :2 , .7.yj,T
?
}, .;y+ s Q; ,; , .. * :
. Sc.Q - epplicable documentation had been sent by the transferring ergsa-
_ q.t , isation witbeat knowing enactly what tbs original specificaties8 ib ' j p , Tri (technical /QA) were. (See sections V.B.4.c and V.3.S.) l
.h .'b
'f. 9 5 '
Reeemmendation l IN::
$/ NUC PR should implement the requircoents specified in ID-QAP 4.3
", ,1
, regarding transf erred material. A copy of the original contract should be in the possession of and used by the receiving site
,, l ., ." during receipt inspection, and QC documentation required with the
'!? transfer should be specifically identified.
L 1 b E. R-84-17-NPS-05, Cable Assemblies at BFN with Assigned QA 1rvel I t- Designations Fabricated by TVA from QA 1,evel II Farts with No
;, Ne c ha ni s m to Upgrade QA Classification a3 Conclusion Cable assemblies manufactured by TVA were improperly classified h s f ' gj{' QA level I items. The assemblies were manufactured free parts with a lesser QA level !! designation and no mechanism was found r
that was capable of upgrading the QA level designation. (See flI q
,. f section V.B.I..d.)
Pecorcendation BTN should take whatever steps are ne c e s s a ry t o a s s u re tha t the 7, cable assemblies, identified in section V.B.4.d. in stock, in use, and fabricated in the future satisfy the technical and QA ,
' specifications required.
', T. R-64-17-NPS-06, PFN Fower Stores keceipt Inspected Material Not Trained to Inspect Conclusion
. l Power Stores receipt inspectors are not trained to receive meter-1 1 with Certificates of Cerpliance or Certificates of Conf orm-ante (C0C), Certified Hill Test Reports (C4TR), or other similar
- QC docus,entation. On at least two separate occasions BTN Power k Stores personnel receipt inspected and accepted saterial with CMTPs. One CMTR was for different meterial than specified in the contract and was not nonconformed. The o the r CMTR was for similar material substituted by the vendor but no TVA approval of
' the substitution was found. Vhile the OQAM, Fort III, Section
- . 2.2 does not prohibit Fower Stores personnel free receipt in-specting material with QC documentation, they should trot be allowed to receipt inspect shipeents with QC documentation they '
have set been trained to interpret. (See section V.B.5.) Eceemmentaties C" Pt a b.co l d revise the CQAM t o t r eh l b i t receipt t are pet t l es of
.[* #'
motettel with U" dee==entatsse Iy h ere r Stores and thet 253
- s ama a and take terrecttvg ect( 4 e teceggery {tg the (gggg I
~ ~ ~
l
- h,. , k. MI-S. Mk..[N,.'.:W.
- q. . ,, ~.4 U.C. . .,
I ',',). ' ;; - '
.,,q.g:,M,.1 ..,-c. ; D, p, C'N.
i
- ~
.. 8. ;
\
- &l';2..E.*.
p4 .3 : 1 O. R-44-17-NFi 07, Material Vith Limited Shelf Life het Reordered
' .[(duf' f,[.i. (' .' is a Timely Manner
.v'.t M... ': ,: .
Coaclusion f - The OQA?! and D171 system of procedures required the periodic
.r' inapection of material with limited abelf life at one half the
% :'.. ,- e shelf life. Through DPM revisions that OQAM requirement was M' deleted. Prior to deletion of the requirement, periodic inspec-tion was being performed (before the shelf lif e erpired) et BTN j
.,.,.'* but not at SQN. BTN required (PJ 16.4) reordering shelf life
,f material with a three-month lead time, but SQN had no require-
- ment. Neither BTN nor SQN were reordering material with suf fi-cient lead time to have new material in place before the existing
( ,' raterial shelf life expired. Considering the latest industry _t.- philosophy regarding shelf life material, as contained in ANSI / ASME NQA-1-1979, the deletion of inspection requirements and Q'
; reordering of items with insufficient lead times to assume an
(,"I ' adequate supply of f resh material is considered inappropriate. (See sections V.B.6 and V.B.2.)
',v, Recommendation 1: T NUC PR should revise the OQAM to establish programs to inspect
.y ; ,, .
...- and reorder shelf life material to assure an adequate supply of fresh material. Also, the current three-month reorder lead time Gr .specified in DPM N77A2 should be reevaluated and adjusted as
.' , J. necessary. ,
l .
'Y H. R-84-17-NFS-08, Materials Management System (MAMS) Under Utilized
.\ . ~ ~ , ,e I i' '
'7 . l Conclusion 7,
The MA?tS system was being under utilized in that its capability
, to track invento ry items usage and to reorder inventory items automatically was not being used. Considerable manpower was being expended to perform those functions manually and the NAMS system was not receiving all sources of inventory iten usage.
One deterrent to a more complete utilization of MAMS was the f act that its program did not have any quality assurance control to c ., . prevent unauthorized changes to specifications or other QC infor-motion. Efforts were reported to be underway to prepare a quali-ty control feature for matts which NSRS highly endorses. (See C section V.C.I.) t Recommendation FUC F1, Fower Stores, and the Materiale Masatseest Services j Setties sbmsid jointly increase e f f o rt s to utilise the MAME ia c. the esset ef fective sad ef ficient meaner possible. ! 2*.- t . _ - -__ .____ __.-. -
W;T;'. I,w...,wm_ . . . . . . . , _ . . .. y
. z.. .,,-[ p.,.c.
i y :2l.* :.u.., / , - _ :.s .
.; > . , .. .y. **.U
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,yy g _... g. g -- _
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- f. -
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.I.
R*M-17-NFS 01,10CTR21 Requirements incorrectly !.ished te Imc PR OA Retstrements i \ g*
$; @:l6*
t +. 4 ' Conclusion f ' -}.'1 r,!(/WP
*d. % ~ Reporting of defects and liability requirements imposed upco i d.* . vendors by 10CFR21 were incorrectly linked in the OQAM to NUC FR
, $Q.,,, quality levels in that if 10CFR21 was determined not applicable then manufacturing quality and receipt inspection requirements E,,g; .
were automatically reduced. In addition, the OQAM, Part III,
. b '
Section 2.1, Appendix F, attachment 1, f o rm for determining Part l !.!Y 8 21 applicability was ancorrect in that if an item was determined l'.,' 7 to be come rcial grade then its affect upon or use within a
' i,' :
Critical System Structure or Cor.ponent (CSSC) could incorrectly
..- be ignored. b'UC FR agreed with NSRS that the form should l>e
. .?.* I corrected. (See section V.C.)
- fk Re c ome nd a t i o n l .'1'[ h The OQAM and hTC FR procedures should be revised to remove influ- f ences of 10CTR21 applicability upon the determination of required i
.; quality levels for items and services, and training in the re-
-t J. quirements and limitations of 10CFR21 should be provided to all I ,. personnel in the procurement cycle. It is further recommended j f /..'s. that the OQAM, Part III, Section 2.1, Appendix F, attachment 1, l j .s . be corrected as soon as possible and separated from the general j ,.
OQAM revision so that all questions on the form are answered j whether or not 10CTR21 is applicable to the itee or service.
'.. V,
.7 .' , R-84-17-NFS-10, Come rcia l C rade Items with QA 1.evel I and II Designations
' I
.s ,
l l Conclusion Cosnercial grade items were being purchased with little or no QA I requirements or from vendors or manufacturern without TVA- j j i 5 approved QA programs and classified am QA level I or 11. That f j ll ., practice was contradictory to the purpose of having QA level 1 and II items with considerable QC documentation attesting to its j l r suitability for fulfilling an intended function. (See section f D I - V.G.) o i
/ Recoewnd a tion ~~"
t/D _ , - , yl i Itcus purchased with no QA requirement \o r 1 r'equirements for l 1 material certifications (COC, CifTR, etc.) and/or f ree vendors or I maasfacturers without TVA-approved QA programe s hould not l>e , perchased with a QA level I or II designation. , s
l.,
' 4 e
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up.g%g, ;w :'?% '. ? 'k h* $.,$ W . Q i.. W ,f. & 5- yi.
,\ '
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,$'.'a .,S E. 944-1bMPl.11, 01e1ity Verifieetion for Coasmie10tede Itest .
g v ' i. . 4"c.W,. .. ! . l p t p ~. c Cooglestee i( l
@ 7%,f;T,g%f. ,m p g t' l ,h i
The use of cosmeercial grade itees as basic component.a places the 4 .
;' l. '
;Cp[.iQd Q '_ roepassibility for assuring that the itse irill f unction as in-The QA p rog ram i 1 1 j
< teeded under all conditions solely upon TVA.
(*.' V ;'. .'. -
' g j . . , ,.' within TVA, at the time of this review, was not capable of pro-
!4 3 . .. - vidtag that assurance because it did not include a receipt in- 5 spectica program which included testing of the ites or comparable I i
%l' , ' ' '
sechanissa such as an audit of the vendor's QA program for coe- t\,l
'hh,.),j oercial grade items. (See sections V.E and V.G.) -
$.: rec #8'y '
l . . i Recommendation Og i i g h c,. O. 7
- 4. ; i NUC PR should establish a receipt inspection program which in-l?Q-cludes testing or comparable mechanissis, such as audit of ven- k dor's QA program, verification of certificate of conformance, g 4.
[i.y':.' p,, , , etc., for replacement commercial grade items that will be dedi- g , cated as basic components or parts thereof, tha t would provide - c. ql. ,7- documented assurance that the item will f unction as intended when d[ 4
.F" oecessary including accident conditions.
- I ,.r
- 1. . R 84-17-NFS-12 Receipt Inspection of QA Level I and II Items by
,. , :- :.;." M i
Conclusion i
,- * . Considering the changes recomend:d by NSRS in this report wit.b -
] ,
regard to the procurement of quality level I and II material and
': < - ! commercial grade items to be dedicated as basic components, the idivision of receipt inspections between TQE and Power Stores, in 4 , (- j j' effect during this review, will be inadequate. (See sections j
. D' V.B.5 and V.G.) ,
p;,g-g . Recommendation l ^..L All items procured as QA level I and II and comme rcial grade
,'-f
',' ite=e to be dedicated as basic cowponents abauld be receipt ,
inspected by RE or others qualified to ANSI N45.2.6. l 1
- .T., '
- 3. .- Y. ETAIIS
( eT l The procurement process was evaluated by review of pertinent KRC re gula tioma , cons ensus s tanda rds TVA was comeitted to. TVA policy i 7 de.cmaests, and various levels of procedures. As part of this evalua- { time the procedaral flow of seierted procurvenents was f ollowed f ree 5 4 , the e1riginator through FutCI. R$R3 attempted to 16estify all points l et eriginaties for p recurvuents for operatima nuclear plaats and incleded the sits, M. IrCD, reseer-surplied itsee with services, end !
* ' tatsrael TTA trame ters between sites and orgaattattees. Mars thes 194 i
r%m -- - - re, sis it tene selected at seedee f rase El"T, 8:K CC, eed the . 5:P sere reviemed . Of these rev i ewd . &5 were e4Iettd iee fwethog I- , pes $ 36 he8ag reffeeestaL8es eI bee!C tT796 ef precgTM it @ I -
) *
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* ..w d.'.q, ' c/. ?" -:a , .elegt.itel, motheatral, sad structural a re a s . These precureetsta *
- d - 3..T. l [..I. ;C Seelmeed items, services, and inte rnal transfers preewred as either
# ,4 y ht.. L eireet charge, Ineefinite Quality Ters (ICT), or Material Maassement
.;. '[ Dystem (Mats) stock ree rde r s . Of those 45 representative P rescu r e-
- i. '/"
aests,11 were followed through the entire review and approval cycle
;[.f. .
g to yTWCE. Of the 11 procurement actions,12 were classified as emer-geocies with the remainlag 9 being normal procurements. il t, . , y,
.o
" Ikaring the course of selecting and following the procurement actions W.,' -
ewt 90 people at all organisational levels were interviewed with rwserd to their function in the procurement process and problems
~1 see+ciated with their f unction. At FURCH, in addition to their fune-G* ties within the TVA procurement system, discussions were held on U.S.
Government procurement regulations and their impact upon TVA. A. Upper-Tier Documents
,, Throughout this review an evaluation was made which compared the P re gula to ry requirements contained within the Code of Tederal O .- Regulations and Regulatory Guides committed to in the WA Topical Report against TVA implementing procedures which included the i Operational Quality Assurance Manual (OQAM), Division of Nuclear
.. Power Area Program Manuals (DFNs). TVA Procurement Manual, Of fice g of F.ngineering Engineering Procedures (EPs), and applicable plant
. " .' procedures. A detailed listing of the procedures reviewed is ihj - '
D~ contained in section VII, Documents Reviewed." Except.as noted b [g' i elsewhere~in this report
.i' 7eiiFved veri ~isiTodpliance witi_gitulator'lr'y quire TVA's procurement programi in the 'aress" hfg'
~
e
~ ~
=ents a'nd ~were
~'
3.R,, ]mplemeited in accordance with. program _ptoJLediary i [,. B. Plants I#
.p. {
*A ,
Activitip at the plants associated with the procurement and { ., ultimate r eceipt ard storage of iteris and services were reviewed. Daless otherwise specified the findings are applicable to both {
~
, i SQE and ETN.
4
- 1. Preparation and Review Cycle for Procurements 1 .
At the sites procurement activities were confined primarily to five groups or f unctional areas of responsibility. Each is discussed as follows:
.s..
.' a. Originator
*i Oece it was determined that an ites or service was
- required for operation of the nuclear plaats, some O individual had to initiate the procurement actioe. and
,g that individu.a1 was identified as the origim ter. Aa 7', idestified ia the OQAM aad ieued is yreetits, the h7 .
egiginater could be any "tessia.aat ensinogr, super-vteer, er reer eelble designee." The orisisator vs {c. . re,p caible for preteries the ysttbeee r m eet se,d yem,~ the - m sm ha a.1 4 , ei 1, ,e ,u r,- l _ _ __ _A
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f.f.WNN. Y' ' l TelbT & l ft.*U meste associated with the precuremest. Specifically,
'l'
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T* h $ './
~
as seeigned in the 00AM, the originater shoulds
- be familiar with the fumettons of the systma
'f:
Qt. &.7[6.:' 7f
'a the procurement is associated with,
)hi?@nY'*
t $.'
- be f amiliar with the system's importance to M['h]. *,:;-'
- safety, and
} J. .~ '
y
- be familiar with the compliance, technical, and 9.5 . '. , ;
y j'~ , quality requirements of the system.
With regard to the above requirements, and in procure- * " ments evaluated during this review, all o rigina to r s "Y. .' ,
occupied positions where the qualifications to fill those positions satisfy the requirements to procure f',': items and s e rvi c e s specified above. In addition, the Tl originator was required by the OQAM to specify com-l
' pletely and accurately on the purchase request as ; 11 '. applicable the following; r1
- technical description of the procurement .;',,4T.p
- component or system of use ,,; y
+
.}.W-'
j i @
- applicable regulatory code ,
I
- QA level :- UA
}' .,
+. g. y - 3'm,6 V' .
design basis
~
- other manufacturing requirements ,
N 3
~~ C
- identify required tests, inspections, and ,t 5-' I
{ i, e x a ssina l ions
- list dorweentation requirements /j6ffg
- specify special handling, packaging, or storage gf 9 ggf requirements ,;
- determine the original EN DES procurement QA requireneute [c x, - 7 6,g[Q$g/,p
- evaluate 10CTR21 applicability
- identify special receipt inspection requirementa N61:6[
- specify the date the procurement is wanted
' If the originator prefered the purchase retweet cw-pletely and accurately as required, ne edditiew1 T. In pree-review of the decismest would be wces sa ry.
- t ice, cwt r a ry te established prwe+srte, the wigtme-
- m.e a rweted te complete the .p6 h; twyeoeg
*a-I
4- 1
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j ,d( %" ,[.l.' . etevretely and cosy tetely for all itees abeve, Tor l
.f.h '
El ? ' D; fp - ' esemple, . the manufacturer was espe c ted t* F rcrv14e informaties oe special handling, packaging and starage
'W'0OJ 'e requirements. The final QA requirements med Fart 21 applicability were specified by the plant TQ s ta f f and
(#[.* if: s NCO QA Oroup, and the final technical re ,;uirements were k, .hl. specified by the plant specifications engineer sad NCO QE Group. {.{ '
- f. i t f/
- MSRS expected to find a training program for origina-b'; tors in place and functioning. None was found nor T *. ,' required. Vbat NSRS f ound instead was a description by g
E' plant supervision of self training. Originators were i, given a copy of the plant procurement procedure (s) and I '! _' expected to learn on their own. As a result NSRS found that most routine purchase requests prepared by the y' k ,,. originator were changed at the site by TQ and hateri-
-u ,
als personnel. Those changes ranged from significant (wrong QA level or technical specification identified) n.' to editorial. i Vbile the originstor was required by the OQAM and plant l procedures to specif y .everything required in all pro- i
- curements, they were not given the training necessary
'Y , to accomplish this.
[ I b' b. Specifications Engineer a.' Once the originator completed the purchase request, it . was sent to the specifications engineer for review of the technical specifications and coordination with FQE, j
- I other maintenance and engiocaring staffs, administra-
! I tive staff, Power Stores, and Plant Manager for their l input and/or approval. Basically, the specifications I
engineer was to assure the purchase request was coe-l plete and accurate. Both EDI and SQN handled this
' function somewhat differently. .7 At BI'N there were positions of specifications engineer
{ j .,- for both Operations and Field Services that were staf f ed with cosineers. For the Tield Services Group, the specifications engineer assumed the function of the originator and filled out the purchase request. For the Operations Group the specifications engineer re-
-m viewed the purchase request as completed by the o rigi na t o r .
At SON the specificationa engineer's fau tica was istfilled by a materials officer free the listo rials Dmit, wbe did not have as engineerlag backtreend. Am to restev t chetcal s pec ifies tless woe I attrert 4.m r M, b,s t the fumett.e primertly fslfilled ky the i materials of f tcer was ooe o f enretiting yt*<womests. j l
o s l
)
l . \ i w l _2.___, qw _ .. l .
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l* _ . ; l ^N '. . .? j l
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Boterials Deits et both SQN and ITN were the principel k .,$[M'd,' f,# 1'- pelate of contact for technical med goality asesroocs l
#.' changes made in the NCO. The IPCO Quality Engineerles 4 4
M Branch (QE) prepered a fers letter to the file with the Od,[r-- name o f the origiastor and TtN persses coecurring try f' fN_- telephone with the NCO changes. It reportedly was the
. $I.T ' matarlais of ficer's responsibiltiy to assure that input '
"A % '
by the originator or Ft)E was obtained before the h'Ne ', ,' changes were approved. On procurements reviewed try NSRS , a va ri e ty o f na me s we r e lis ta d f o r the origina to r [ig/. . ' concurrence on the QE fore letters and most of the time D the individual was other than the originator of the purchase request. Some approvals were by technical 3
.J . .
personnel and others were by the materials officer. In
- all cases the plant TQE engineer approving the purchase
- 4. .
l
'jf
' requialtion concurred in the NCO changes. The materi-
.,1,'
als officers are not technically qualified to approve f either technical or QA changes on their own. Contrary 4, a
'f- to obtaining the originator's approval for changes, materials officer concurred in the NCO proposed changes U .:' for the originator on four specific instances (FBs
.f '-h " ,
342988, 951133, 951028, 951134). Vith regard to TR 7f. . 951134, correspondence was found in the procurement C ;.
' file which showed the originator was aware and agreed l
,Q'Y with the change before the snaterials officer approval was given; however, in the other three cases no similar f
g I d 'y - correspondence was found. With regard to TR 951028, the NCO added a technical requirement in which the 4 $-1 materials officer concurred and to which the vendor . Q. took exception. The plant wanted zine-coated sheet-
! p The NCO added not chemically I octal, not oiled.
l' u,. q , treated. The vendor quoted chemically treated no oil,
- and the site materials officer approved the exception.
O The site materials officer should not be concurring in I ? technical changes.
"~ c. Field Quality Engineering The Tt}E was also required to review quality level I and 11 purchase requests for completeness and accuracy and approve thee. At both SQM and BTN one individual in each TQE group wee assigned that responsibility. NSRS l found that in addition to the procurements of quality g
level 1 and !! saterials and services, which this review centered on, that engineer also reviewed all QA [,f levet 111 and IV procuremente as we ll a s ace-CA p ro-l1 rurveests. Virtually everything procured by the sites I was s py roved and/or reviewed to as sarle the p reye r k goality level and requirvesrata had been placed spea the i tse be imit p r < m red . To y,st perspective es the mapai. l tede af nat effort, 171 Pome r Storse prearited a cour, F ilation of precarenests (or itay and June IM4 eh,wist g# l ItSI pree we veen ts , bot did met she here eary wm
-* ,=a1ity levei 1 er I!. Ihat souber of Pocuersta o
q1
.. 4 m ~ n- = : _n,.,.
g
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h g y===_wsnM=- 2:-
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f l,(4..lf.5-..[j'f.Of-l . h.l) L l[ [ [.' ]'s Vjf,hjgy'% N y M Ql.M '" 3 LTe?J: M . m m, - l' '}4.f! 9 di *, . i
'L' n.h': &..".:l'
-- c.
'( -:i'd.v.s.h ,
- would result in as averags of abest 26 per day requir-T-2' it7;'T -
Lag Ft3 approvat sed /or review. s$. h: r%:~g.
' ;1 '. , o{., The PQE review of purchase reque s t s wa s described is kl, ' '.' 'T - the OQAM es including both technical and QA require- ,
' gt , % meats. Depending upon the ites or service being pre-l 1 p J; . cured, TQE described their review as including a coe-i? N- ' parison of the technical and QA requirements wit.h plant
) drawings and previous procurements of the some ites.
3 i [l'.T: Although MSRS did not physically observe this type of h,'.'
-y,7; i Tat review in process, the mechanics involved in per-forming it could be time consuming. Considering the
[ 'f , . ' e.* " ... number of purchase requests reviewed, the courpleteness t fi) ~ ^ of each review is of concern. TQE described t.he number of procurements found with QA levels lower than re-
,' quired as ve ry few. The routine review of non-QA
; r *. procurements by FQE is, therefore, considered too time T' consuming by NSRS for the benefit received, and the t ,j., time expeuded could be more effectively utilized on QA i
l soupling of y..,., procurements. A periodic review of a p non-QA purchases should be sufficient to detect program s , deficiencies. 1,. ; . g, d. Plant Superintendent
?
~ i[ n ' L'pon completion of the review sod approval cycle of the j; ' , purebese request, the purchase request was sent to the
- 4. ,
plant superintendent for authorization. -
.. 3
} S.,M. = e. Power Stores I
l :
.7- .
( ! The purchase request with all approvals and authoriza- )
't . s .
tion was sent to Power Stores f or determination of the !
. appropriate wthod of obtaining the requested item (s) ]
-- and preparation of the associated documentation.
Methods available to Power Stores included direct i
, charge procurement using a purebase requisition, re-l quest for delivery under an existing IQT contract, C.
field purchase order to purchase itema of less than
- $300 from local suppliers, or a transfer requisition A (TX) used to transfer items from one TVA site to another. Once the method was selected, Power Storen would transcribe the approved purchase request writeup z
4 verbatie on the appropriate form and add on all the
*' perchase request attachments which could include QA and y
techsical specification requirements. Prtrcitrement i i i forms prepared by Fower Storse ve rs defined as QA
$ d+cuments in 0%M , Part III. Section A.1, wberses
[ Parthese requests were vleved as worksheets and not QA 1 derunesta. The o!!tc1ei QA derumest rettites the [ sipsatsre of TQC a n.4 the plast supe r tataedent. C=e-
**t***t a r b*th TOL end t he plaat surtriatandest vers
^2 sipalst the sees rrocarseest attiem tvttg.
^
l
2
- i e
cm e . I n n~ - m- - D W#
- s) f.,S;h'Y L,. '- ' .. ,-*
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g- T _ g - 3p p!:ssc:
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_=_ 4.J g, f ,. ; s .. y . *r.{ . s 7 , 7~3 jl *;,. . d}Q. . , s, '.'-l . ... .- .
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.a .
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hk'.[ w
;ild"kgN:" J<
- Tbs ysrchase request se described te tsRS was met ree-eldered a QA document be caus e it was set alw*Fs pre- P
?. pered la indelible ink and could isde with time. The -
OQ41, Part III, Section 4.1, required QA records te be {('i[.d5.$7 ' p repe red la iak er typed. la conf 116t with that phi-i ,-{M'Q. . y :. f lesophy, NSAS ebserved attscheents to purchase requests d.' U. g ' ' , ' (e.g., 10CTK21 applicability form) that were prepared ; , f' '
*******17 8" **** '' "*** * * * * ' " ' ' ' ** ""
,I"( id .'. ',; * - 4+cunenta.
In addition to signing the p rocurement form for record
')d ;
purposes. IyE was required to review f or accuracy the l :g'?.'.$l
'l' documents prepened and attachments included by Power Stores. As TQE was the last to see the purchase 3 .yi , request prior to transcriMion by Power Stores, their
' review of the finished product was editorial in nature, l .'. c ,y;
' TQE, therefote, was required by the OQAM to duplicate s.f - its own work in reviewing and approving all QA level I
[ and 11 purchases twice. j tj". , ca Like FQE, the Plant Manager was required to duplicate bis work in authorizing both the purchase request and Q*t purebase requisition. O. With all required signatures obtained. Power Stores g ;.Jr.' y then transmitted the procurement package to Chattanooga 5
' for additional review and approval prior to going to t
-j?.
4,. Purchasing.
,f
- f. c 2. Tunctioning of Plant Procurement System l .4! I
)Q i...' Overall, the procurement system used at the plants contained T t !
J i redundancy and was predicated on the concept that additional review will promote a better product. As a general rule, a
; c' procurement f rors the identification of need through trans-mittal of the rompleted procurement pa c ka ge to Chattanooga
$ cont.a ine d 10 signatures or initials signifying review and "g%
approval of the procurement. Ge nerally that preparation
*7
.6 process was not considered e s c e s s iv e--ta'a ing 4 days for r,g normal and emergency direct charges and I day for an emer-gency RD under an IQT contract. More coeplicated procure-i ments were seen that required I to 1-1/2 months to prepare.
Of the 10 signatures or initials in the approval process, l only 2--the o ri gina to r and FQE--were identified as having l
- sey substantive technical or quality contribution regarding the specificaticas or requirements of the procurement. ,
Pere emel intarviewed were generally aware of their function , in the TVA precerement process but generally maavers of the i ismeties med respeesibility of other sections in that pre-l cwes. 'With the possibts esceptice of Power Stores, knew-ledpe of T*eeral procurement re gilatiets wa s lackist enest these is the y r,cu teers t tru ees. Ter example, me oese et
- g. .
s
,w) ,
.. x y
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wxry n MM,--h
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g f' g,gY. g m.1.:. ' -N:l. r.%, % . , the plaate or elsedere within TVA kaev how leeg it sesselly teet to preewre eseethlag. They knew it t+d t+e int
**d l,gj' Q.h. UNh.[l. ,
/.$g.y- seleen arrived whee needed. The originators wuld allow 70 esys, is establishing a date wested, f ree the time a rur-g p ' Y+ . f1
. " thee retwest was inittsted f or rentina ocesassrgeneT Fur-
.g.'@ [g,,,i y%
-e chases of resunoa iteme (nuts, bolts, steel, etc.), estil these itees were orpsetad onsite. That date was virtually
[,{,g*
. .; s igeered throughout the procurement process. As a result,
,,g.1'f ;l.--.
the purekase requisition rarely arrived at Purchasing with
*Ut ,-, , sufficiant time remaining, until the date wanted was passed,
; i i?.d , to stvertise for quotations, let alone time to review the quotations, award the contract, sanufacture, and deliver the
%(l . ites. Of the requisitions reviewed by NSRS, it typically l 7, c . took 6 sionths to 1 year to receive material onsite and the
{g ' - sites were only allowing 90 days. With suf ficient training 4:g ; in and knowledge of the procurement process, personnel p.f within the procurement cycle could establish more realistic
,c:
timeframes in order to receive needed materials. tj ;., N Probably the most frequent coerplaint about the procurement [;, . ; ' process expressed by the sites was the material was not there when needed. That complaint results in large part I 3 i'f f rees the unrealistic expectation placed by the sites upon (.j;*Q the procurement system. The site routinely wants rapid resulta, 90 days or less, and the system can't handle it. g{,;[ l f.5. ', 3. Planning g; ~ ' q.* Planning of work for a:ainte na nce and outage modifications s, y ; .- was not a formal part of_the review; however, the obtaining t*, '.- of needed materials to perf orm work was reviewed. As iden-I ( ^Q* ".~ . f tified in sectico V.B.2 above, ordered material often g i ;~ , arrived at the site after it was needed. There was no one g ( factor producing that condition but several f actors begin-
'i .
ning with the originator and including all steps through This reviev receipt inspection of the material onsite. d- , / found, bovever, no evidence onsite that materialTor availabili-further
/
ty was fortered into the work planning process.
.,D Information on planning see NSRS Report R-84-27-SON /E7X (GNS d $41220 052).
- s. Ter example, in ECN modification work, site personnel ex-
'. plaiacd that a complete ECM package was not received free Portions of the ECM package would arrive in stages
; ' '*. . EX DES.
ever some time period. When the sites had what they be-I lieved to be a sufficleat amount of the EG package, work weeld be schedeled sad meterials ordered. Eagineers at the site la charge of the modification work and ordering materi-
- the meterial eteer*4 woeld prskably
?-' al r-aly stated that Coasteering that
. errive before the EG work s ta rted. l eely to ders wee a11ewed ier ytenremesta thet egeetinee teet 6 seetbe te 1 Tver te yet, that empreteed toectra was De eif ert weg ie=ed, however, te tacInde a
' me11 ieas4 4.
sere realiaste timeframe la the ette pleantag yn nes. I
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.b What resulted, whe n the material did not arrive, was sa
~
I eserties la resourcefulness by the sita engineers, etich they appeared te be very good at. he engineers had gs find j .- -j M
' bpTS,l5,/,
the material t. hey needed through borrowing it fross another
. ef;[yy _ engineer onsite, finding it at another site and haylag it W. transferred, or initiating an emergency purchase. Effective
' f. #$' .f[ g.J '.
as the engineers may be, tha t effort in resourcefulmass is
', . .l.M ' s time consuming and waste f ul. With more effective planning a
_V "J' ' 7,- .f - significant portion of the time wa s ted on obtain.ing ma teri-
. M,; $; " ;. als could be eliminated.
?$. 2.
- 4. Special tiethods -of Obtaining Magial and Services T:' Huch of the emphasis within this report is generic in nature 3 .h and applicable to all types of procurements. The sites have numerous methods available for obtaining material and ser-jh vices with direct charge contract being the most coenon.
'# This review examined not only direct charge contracts but I
"fg* :
other methods as well, and this section will focus on the i less comon methods and their associated strengt.be and
- veaknesses.
- a. $_ervice Centracts Often the services of consultants or workers with
, i~
specialized expertise it required. Like materials g
- bring received at a site acquires a receipt inspection, I
the receipt of a s e rv ic e at the site also requires an g [ f, , ,
- evaluation and acceptance. Acceptance of a service is Identified in the OQ Art , and three acceptance methods Vf paragraph 10.0.
I are listed in Part 111, Section 2.1, I On two separate occasions, SQN obtained the service of Furmanite, Inc., to stop leaks which could cause a shutdown of the plant. Those services were requested by purchase requisitions 959104 and 955163 which speci-
' fled the vendor shall comply with the technical re-f
' quir-ments of IQT contract 82F38-925403. On one occa-l
' sion a Gulf and Western Service representative was requested, under purchase requisition 940060, to per-forn work at SQN. In all three requisitions it was
~
specified that work was to be per f ormed and documented under TVA procedures and QA program. On four separate occasions SQN techenical maintenance and cosyliance personnel were asked for the .tocumentation contained in the work packages or elsevbere for those three com-D
' tracts, vesch satisfied the acceptance of service requirement o f the OOArt s pe ci fied abov e. It323 did met I
receive any each documentation or an explanattee of bow the OQN1 was satisfied sad must therefore coecleoe t. hat m :* it 4+es met esist. s.
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1!dN - c. B \*fB?l Jedettalte Quantity Ters (107) Centreets b. w.
>p~.
n . .s ). . ,IN ~ IQT contract can be a powerful tool wbes procuring Am
.,. the same item or service on a routlas, repetitive S...C.
yf2 E ./ basis. When such an ites or service is identified, am i J .*. j. .' ' IQT contract can be prepared following the same preper-as if it were a 9 Jd' ,
- etion, review, and approval procedures y iff.'
- direct charge contract. IQTs are advertised, sent out
'py . i for bids, bids reviewed, and contract awarded so dif-
-( .- ferently tbac a direct charge. The difference is, or
-! is supposed to be, that when items or services are
.[:I required under the IQT, a request for delivery (RD) is
'y.. prepared and sent to the vendor bypassing the review
,9 and approval process. That procedure was described as r being followed by EN DES, but not by NUC TR. In each
- J. . of the NUC FR RDs reviewed by NSRS, the RDs vent
; '4
. ' through the same resiew process as the original IQT,
' .I ' therefore eliminating any savings of stanpower or time 4 gained by having the IQT. Arguments were presented that l -
the IQT was not an actual contract, the RD was, and l j therefore, had to go through the review and approval process to satisfy QA documentation requirements. It
,' was also argued that s on:e times not everything pur-B y chased on an RD was covered by the original IQT.
y . ., s].o . ' With regard to the first argument, the IQT contract was The RDs y ( z. retained as a QA record as were the RDs. i 4 ...
*- specified wbst was wanted and that the terms and condi- .
) l i.' i ' - tions of the specified IQT were applicable. Each RD p ,y was reviewed onsite by TQE and an authorizing official.
j.: [ In NSRS's opinion that should be sufficient to satisfy 7 ,,- - l QA r equi r e sie nt s and the RD should be sent directly to
.., the manufacturer.
With regard to the second argument, NSRS views that as E a cospletely separate issue. If an item or service is to be procured that was riot initially contracted for and a change of contract was required, then it should i as a new go through the review and approval procesa procurement. The .idditional review of all RDs by the central office only resulted in additional verbinge added to the RD vbich was already contained in the IQT. This vos coa-i. sidered redundant, unnecessary, sad resulting in need-less time delays of 20 days or more. The elimisation of the central office review by EUC FR s W ld altalaate the pr+blee provided that in transferring the tesittel etits e resit ices to the sites the pedles was cet
~
^.,
treasterred as well. That trasaf er we set etsluted 3, , se a port of this review. p, Is t he p r oc e s s of evaleettsg prec,sre w et et th sites, a number o f di re< t c ha r ge preterasetta tot stvet v m
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' ' ' observed at each site.
It would appear that an IQT [ D/fM - contract would be beneficial for t. hose. y j!)4$-l'..d h~f -
- X V. ' ~ .... A problem with IQTs developed and was apparently solved l
M90i
. /'!
- during this review. It was determined by OGC that RDe for stsator than $10,000 would require advertising in
., a
. ~ slp' l,e -
' the Cousserce Business Daily as if it were a new pur-3
~ OGC later determined according to NUC FR pe r-F chase.
f' j h p- l sonnel that a periodic generic advertisement would be i fD.' ' ' sufficient to satisfy Federal procurement re gula tions . g
.j'gI, ,
y
- c. Transfers
. .e! ,,
- p. Although the transfer of material within TVA is not a i.
, 71, sense of the word, transfers do h" procurteent in a true N .
provide another commonly usedAs mechanism of fintroducing j such, trans e rs were new materials to a site. 2 is reviewed as if they were procurements f rom outside v 'y. vendors. k Hany items have become available for transfer due to the cancelled units and are shipped to all nuclear l sites from HrN. Other tr.ecsf era occur vben one operat- ((j. 7 ing plant or construction site has unused material fi which can meet an emergency need at another site. $< FOTE: Transfer of electrical cable was not pur-sued by the review team at this time. Both PJN f . '- and SQN personnel identified documentatloa prob- g lema occuring with cable which resulted in a large Basic , n a.l ..,., number of nonconformances being written. problems as told to NSRS stemmed from lack of
.i . - g
,Jg . coordination between the Office of Engineering l
. 3 I
(Electrical Engineering Branch) and the site and j erroneous documentation accompanying cable trans-t
'.4 '
ferred from HTN. Most participants were already f aware of the problem and appeared to be working on a solution. The implementation of the solution - will be subject to review in Phase II of the NSRS
.> procurement review.
Torm TVA 4139, " Request for Shipment of Material," is U k' used as the means to transfer items between divisions A d The form includes descriptive (NUC FR and CONST). h ' information of the item, Fort 21 applicability,ID-QAP signoff, and other miscellaneous signatures. TQE 4.3, " Transfer of Itema," states that the following steps are to occur in an interdivisional trasafer: Y f (1) Requesting organisation establisbes a sects of avs11shle itees, l S. . q (2) Ret.esting ergestration prepares re w et for J ! g g, "- treaater. a
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TVA Tabricated Equipment i .
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Another mechanism to introduce quality equipment into fy
! 7 tbs piants was for TVA to manufacture the part from p d [..s ' ' , ;f ;I .' ' This review bad planned to include f!,d'Pf.f ;"I I i stock material.
l l work perforwed by the Power Service Shop for the j d .'@,'fM* nuclear plants as if the abop were another vendor. This , I :* ![f.
- was eliminated f rom the scope of the review after the
. .[ " .; BTN review segment because of time constraints.
g.'::,,:- Before the TVA-fabricated equipment was removed from f j /.(' C (f,I! t. the review, operator console cables and control fes-for t.be BTN refueling platform andbyJibRTE crane were g toons fabricated electri- , M P.!s - identified to HSRS as being Completed control cables d(g'. '
- Mal saintenance personnel. y,j classified as QA level I items and '
@.~
3' s h[f j9 d festoons were the Power Stores werebouse. Documenta-obtained on the manufacturing process and '
# fgtockedwithin tion was I t vo s de te r-h .h) materials used to fabricate those items.
from I
/#
... .h l 0 mined that each cable and f estoon was manuf actured level 11 parts and nothing could be found that ((j Iy - abowed how the assembling of QA 1evel II parts produced p' d p [' [j'(f p Q a QA level I finished product.
management, they assured HSRS the matter would be Vben identified to FJN
'F
*7-'.
k corrected. d
- :! . f,5. Receipt lospection Program -
' *;f.;
j. d; was g 1
*t. The NSRS review of the receipt inspection program y,
,g' ; i.:
limited to a review of receipt inspection reports and asso-Actual receipt inspections being ( i j j%y ciated documentation. 'the review effort consisted of
,- 4 perf ormed were not observed. rand.a tres the Power Stores files , h l '6 selecting requisitions at d
{ *; ' and verif ying that all documents requested in the contract , The ' proper group performing receipt i C I had been received. required by the QA level assigned to the ites - j .* ' ;, ' l inspection as Power Stores personnel only or Power Stores was noted, i.e., Selected personnel from Fower assisted by TQE inspectors. Stores and TQE were interviewed to verifs their understand-g ing of receipt inspection the procedures. Those interviewed g g of NUC PR requirements and site y [ appeared knowledgeable g y
;, procedures.
at the nuclear plant sites The receipt inspection program t.be i-3' was directly linked to the quality level assigned to / material belag received. As such, material with higher . h I ' inspected by IQE inspectors and material quality levels was
- with lower or no quality level was inspected by Power Stores .
~'
clerks. The typea of inspection performed in those groups had varying degrees of dif ficulty associated with them, significantly and diffet-l ' therefore, the inspector trainlag was 4 est between TQE and Power Stores personnel, I j j,0 n . gt i rg n G 4
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- TQE inspectors secording to the OQAP! perform receipt inspec- (itees tion of all QA level I, level II substituted itees
,' asbetituted by the vendor as being equivalent to which 10CTR21to those asked applies and W,7;. for), level 11 and gCMthe ltess E/;ll:T .$ ,f..M '. ,..UT;-
- vendor directly to NUC FR, The which are ' shipped f rom tvp'(f{%'D.'p - ' Ft3 inspectora receive formal training and certification through the Power Training Center that meets requirements I.y((..
M ' ' '". ;/ ',-d e' . [,. established in Regulatory Guide (RO) 1.58 (which endorses
<kj; AMBI 45.2.6).
h"S. y @ ~;. . clerks according to the OQAM perform ' Certified Power Stores of QA level II non-10CTR21 items, QA level III, - inspections h[*T dy QA level IV, and ECN sta te rial transferred to NUC FR f ross
' TL,W s CONST regardless of the QA 1. vel. The Power Stores receiv- ,
l} /~ ing clerka must be certified by the plant QA supervisors. '
) J r ,a.y, . To become certified, 550 hours of on-the-job training mus t
-j g-l be completed and an esamination passed with a score of 70
.'/,
/f" percent or better. Recertification was required at inter-Power Stores personnel were
. 2!. ' vals not to exceed 18 months.
also delegated (by the Topical Report) the responsibility of inspecting comunercial grade items. 5
,3 f. ~ , The separation of TQE versus Power Stores performing receipt O inspection occurred at QA Level Il and was determined by the
' .S applicability of 10CTR21, " Reporting of Defects and Non-
{;, compliances," to the ites procured. j: I The documentation associated with the QA level II items can N-f i.b , . . vary from certificate of conformance (COC) and certified 8' material test reports (Ch 1) to packing slips. During the course of the review, no consistency could be established "f}l for documentation required of QA level II items. For with Part 21 applicability could - example, QA level II items
.@ . require certificates of conformance p ovided by theContracts manufac- k W P- I turer and/or certified materials test reports. ;
. f' ' I for QA level II, Fart 21 not applicable, coel'. also have the previous same requirements and/or a packing slip.
.p; p
If a packing slip is the only documentation requested on a requisition, tbe inspection is essentially a number check T. . and the on-the-job" Power Stores training is acceptable to f
[ However, the appropriateness of h perform the inspection. reviews (such as T
' Fower Storca personnel performing document COCs and CMTRs) that they hav.e not been trained to perform against material received is iguestionable and of concern to
. NSRS. T.zamples of Fower Stores receipt inspecting Of7Rs on QA level II (Part 21 N/A) material were identified at BTN.
tiaterial requested was to be citber ASTM A336 or A479, type
.,'I, 316 stainless steel. The CMTR received with the material C
s pe cified results f or ASTM A276, type 316 stainless steel. l The itene weren't conconformed. The difference in material l was being evaluated by BTX P9A Staf f et the conclusion of l the review.
'. 1.
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m~ A baals for 19CTR21 nonapplicability, in the IrDC TR strue- . l
#~
/gD 's ture , wasA the determination of an ites to be "coesme rcial i
r grade." coussercial grade ites is considered to be an 9 industry manufactured standard product with sufficient use
& bistory in non-cuclear applications to justify its use in a y nuclear application. Vben Part 21 was determined not agTli-cable, Fower Stores receipt inspected the item.
ANSI 45.2.6, " Qualifications of Inspection, Examination, and inspec-Testing Fersonnel for Nuclear l'ower Planta," defines tion as: A phase of quality control which by means of examina-tion, ob s e rv a t io n, or ocasurceent determines the con-formance of materials, supplies, parts, cosponents, appurtenances, systems, processes or s tructure s to predetermined quality requirements. J ' The personnel who perform those inspections are required to 1 also neet the established stardarela of inspectors as speci-
- fied in ANSI 45.2.6.
If an item has no predetermite d quality, then an inspection as defined above wouldn't apply, and the Power Stores clerks i,'.
.,[
' performing receipt inspection wouldn't have to be trained to ]
ANSI 45.2.6 requirements. ff'y.y ,, commercial grade ites l
.' The inspection and treatment of a
, takes on new meaning and becom s quite important if the iten I
. gf." y7 / ,
- is subsequently used as a besie component. The Code of v., d .h p',' . Federal Regulations in Part 21,coariarcial " Reporting of Def grade itesects canand be s
[b ' Noncompliance," states that a ,
.m,
.El . *, . ' '
designated for use as a bas,c responent through "dedies- .
~ tion."
The dedication precets la basically TVA accepting l
> .1 responsibility for the quality h,5 Whensnit TVA performance
.iccepts that of the dedi-responsibili- [
cated co==crcist item. 1
'].'
ty, there should be sorse dorusi nteil assurance of the quality [,' ',F, . of the ites.
} {c.' , j
; ;s4 ' That assurance could be estat11shed through meana such as I
- Je' the following:
r [ (1) audit of the supplier )n (2) testing of the item (3) verification of certificate of conformance (4) assist 41 ming records documenting supplier history
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[ . p' g - i. A basis for 10CTR21 nonapplicability, in the NUC TR strue-ture, was the determination of an ites to be "coussercial L a .. , - 4D r grade." A commercial grade ites is considered to be an industry saanufactured standard product with sufficient use h h history in non-nuclear applications to justify its use in a g nuclear applicstion. Vben Part 21 was de t ermined not appli-cable, Power St res receipt inspected the ites.
- e. -
l
': ANSI 45.2.6, " Qualifications of Inspection, Examination, and Testing Fersonnei f or Nuclear towe r Plants ," defines inspec-
, Lion as:
A phase of quality contr .I which by means of exassina-tion, ob se rv a tio n, or oc.s s u r essen t determines the con-formance of materists, supplies, parts, coeponesta, a pp u r te na nce s , systems, processes or structuries to predetermined quality req.irements. 4 . ., y The personnel who perform those inspections are required to 1 4 also neet the established stas.dsreis of inspectors as spect-
^ fled in ANSI 45.2.6.
v z';
' If an item has no predetermin. d quality, then an inspection as defined above wouldn't apply, and the power Stores clerks j,$ ,..; performint receipt inspection wouldn't have to be trained to y c.,k , ANSI 45.2.6 requirements. ~l
'M ,,
coarse rcial grade iten The inspection and treatment of a
.@w n . .-jt'i'. takes on new meaning and becours quite important if the itee
- g. *a- v' l is subsequently used as a b.isic component. The Code of 34 N O -
Federal Regulations in part 71, " Reporting of Def ects and coarsercial grade ites can be s Noncompliance," states that a Q'g[.l,f,g' '; p" ' : ( designated for use as a basic component through "dedica-j p * .e. tion." The dedication process in basically TVA accepting j responsibility for the quality snit performance of the dedi-
, I.3 - '
@ When TVA .iccepts that responsibili-c a t e d coasne r c i a l ( t ers . docuawnte.1 a s surance of the quality k h i ty, there should be s orse g /~f'~#[ F '
;["y:,
of the itea.
, iv.i That assurance could be established through means such as
- f v: the following:
. L. . ,
Vi' ' (1) audit of the supplier (2) testing of the ites t . (3) verification of certificate of conf ormance g (4) meistataims records documenting supplier history
s t i A
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previously identified concern of Power Stores personne -t performing receipt laspection en materials and important related [G7p-[%j,QO r
.l N d'Ci. Q l .
' 1ir.; documentation
; with einimal training becomes more 3 ;l
.p t j. ,*, yp; , - .
~
' G whos realising that commercial grade materials can be dedi-y.
~****0.as basic components.
M ' h <j;j T,id{N. T# gi)..,I . * .. f In many cases, the Power Stores clerk is the onlyThe one who a' 7 f.d,9 ,G'c iepor-f.. . g'c. ? has evaluated the qas11ty of an ites bef ore use. i-Lance o f the inspection has gone beyond the basic invento y / / N.J.7,- -7 f. . l ' h, of itema received versus items o rde red and should be per- ' 4 JDjf.h{ f . L..f. f omed by TQE inspectors who have been trained in the review g
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of documentation related to procured items. j";:p' '"; ,;g ' T& However, it also should be earhasind that the TQE inspector is basically look- 4 f"-[,'p,' ;, '
?:
receiving the certificate of conformance ing for a signature. The review te am did not pursee the ( ; J
.t.. validity of COCs but did observe the followlag l ,%' ~., , (1) No testing is routinely performed on material to verify s material properties as statedincludeby the testing manuf methoda.)
acturers.
- ,'E./
(FQT. f ormal training doesn't l
$'h'. e-g.r. all vendors who provide COCs with coeraercial Thernfore, grade the ,
(2) Not material have been audited by TVA. 73' fih value of the COC would be in question. p.- , g
-.t. (3) Supplier and product history has not been The maintained os re f o re , no ,
l a, '..' materials received and used onsite. s documented bases exist to substantiate the acceptabili- I g d],;._ ,i' ., ty of an item on that baaia. l i?,. commercial grade items supplied by a
...t r . - * . As a result, for true -
i D'@.' '. vendor without an approved QA program and with no supporting for QA documentation, the only assuring activity remaining 5*,iy , . . M w ', ' ' TVA is testing of the item. No program was identified that tested items uper receipt. As identified in section F.C
$,O.k[.
U- ' ', ,.~h',', g' ,#<Yl '.2.; I there are no TVA controls over the manuf acturing process or / -
%, r' materials for true commercial grade itema that could assure /
flDW ! ^ " that the materiala of construction and operability of an g.M -
*[ item is acceptable for its intended purpose or its environ-q ipy. ment of operation. -
)
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,u
. :n... J;.... NUC PR personnel stated a functional test of equipment was ,
h
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,' required when repaired or replaced. That test should pro- G rn
.jJ, vide suitable evidence that the ites That functions preperly test will not, ,{
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i; i.,,a. ' ' 'A' . under normal eperating conditions. ~
' iy.
#i bowever, provide any assurance or demonstrate an ability of 3. ,f l F,W[{'j'I #Wk ', that itee's functionability with respect to time or environ-1
- f,@ ,
o. mental conditions present during .in accident. As such that @ v
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N[,f.y . functieaal test is unsuitable for assuring a commercisi g <
. ,y f
{. , , grade itse maad as a basic co.-90se nt will functice as _gg required daring accidest conditions. ,; Q,{[.'. fg.[h- .i.:
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g at least three months prior to their expiration date. As p stated in section V.R.2, three months may be an inadequate - g lead time. f r.p y: III, Section 2.2, paragraph 4.3, " Inspections," stated Part " [ A .J ,g that " Inspections shall be performed and documented on a , L periodic basis to ensure the integrity of the item and its g ..
*di
/1, container is being maintained . . . specific inapection ,
r requirements for equipment and material are delineated in ' DPM M82A17." That DM1, which did not cover all items with a ebelf lif e, was revised on September 7, 1984 removing the [. inspection criteria. I i-Consequently, whatever inspection process was intended by h
,1y the OQAM reference to lower tier document requirements was ,
lost with the revision of both DPMs. l The Power Stores personnel at SQN and RT11 had different
- procedures for inspecting and reordering ma te rial with a -
c' shelf life. t1sterials were being ins pec ted at SQit nea r the sa J exp iration date and then reordered. BTN was performing inspection when material reached about one-half its spect-fie.1 shelf life but assigned a low priority to the reorder-ing of those materials. 1 SQN Power Stores personnel did st ate that a shelf life item inspection program would be initiated in the . ar future, n r but no specified date was identified. The prog eo described
- would provide an inspection at six months pr.er to the expiration date.
' h' '
The BDI site procedure BF16.4, Materials , Componente , and , l Spare Parts Receipt, Handling, Storage, Issuing, Return to I h , ' Store Room, and Transfer," was reviewed. ET16.4 referenced
-;(,~ .
incorrectly DPM N77A2 for the storage and inspection re- vos 3 quirements of shelf life items. BF16.4, section 4.8, l ;~.. ! . consistent with DPM N77A2 and required the reorder of shelf ** 5 life material at least three months before the expiration j date, [ ', 1~ 4 ,-
' In order to verify compliance with the BT!6.4 inspection requirement, three months of computer printouts (May 1984 through July 1984) were reviewed that listed all shelf life stock itema due to expire during the month. A checkmark
V) had been placed by each ites by Power Stores personnel verifying that an inspection bad been performed. That type i
. of documentation did not meet the requirement of OQAM Part '
III, Section 2.2, paragraph 4.3, which stated that a form g- similar zo attachment 4 of that OQAM section abould be used' , for taapections. [ [ ; At RTN five items were selected f ree the June 1984 computer ' . l listing to evaluate the shelf lite taspection process. Of ' j , the+e, two itsea were judged by BH to be is acceptable [ 0 .d
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Sk.D b ~ condition and their shelf life did not expire for anothar la contrast,
- Y -h{ ,:j, year. Therefore, no reorder was required, ,
[. .C , three of the items were due to expire within thres months hW g; . , and had not been ordered, i.e., a purchaos request had not ' 9/'5 3 ; e been written.
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' E.
[. It was emphasized by Power Stores that those small quantity ^ {d 4c ~ items were not being reordered until a larger quantity order
'" '^
could be made. Certain constraints regardina the minimaam l k' dollar value of orders were imposed by FtIRCH and mnisetar-
' ma te ri a ls
[f.[ .'s ^. ,. . ~ s era. Wile the size of an order may be relevant, The consolida-i should also be ordered in a timely manner. . 7 tion of orders to make " quantity orders was the respocal-U' '[ bility of HMSS. (See V.C.1 f or details.) y Wen meterial exceeded its specified shelf life, which appeared to be a coarson occurrence, specific approval by PORC was required at each site to use the outdated ites.
; Nore recent industry philosophy regarding ma te rials with
.r f - shelf life is contained within ANSI / Astm NQA-1-1979, Supple-E. ,
ment SS-1. That standard requires that shelf life itene be
- 1. identified and controlled to preclude the use of iteme exceeding their shelf life. As auch it appears inappropri-r1 j ,
ate for TVA to r e s>ov e requirements regarding shelf life inspections, and to continue the practtee of reorderias s material as the shelf life empires or wit. bout suf ficient
, lead time to assure a supply of fresh material.
i .. . 4>.
.i,: J' C. Fever Stores l "'h 1. EpN and SQN Tower Stores J '.
The initial review time in Power Stores was spent gaining an
- understanding of the basic occbanics of site procurements (forms used, t e rmi nology , coordination required, time f .
I delays, etc.) and reviewing procurement files. Power Stores l ,, ; l maintains a file on each procurement, which includes all
.g available information relating to the specific procurement y' ; (request, requisition, receipt inspection report, etc.).
- .. Thos; files became a main source of information for the F- review team end, with a few minor exceptions, were essen-tially complete records. Various personnel were interviewed
$ to ascertain their understanding of the totsi procurement and system and to identify their specific responsibilities
' problems within the procurement system. These intervieved appeared conscientious in the performance of their under-stood responsibilities and demonstrated a willingness to assist the review tree in locating documente relating to g ePerific procurements. Aress reviewed included the auto-g q mated reordering of stock items, the utilization of the tWtS '
e database, the shelf life item inspection program, the Power 5 E associated training, sa4 **
- Stores receipt inspection program, E
kandling of records. (The receipt laspe ction proarse eed storage of shelf life itees were previously discuased in secticas V.8.5 and V.3.6 respectively.) 3 j s 21 _ A . l 1
)
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e Power Stores personas 1 were responsible for typtog requisi-l . !Yl . tions and coordinattag all the required signa ture s . They i ( $
- alsu helped locats assded materials within TVA by utilising F I d[y[._.. . . availabls information on the MANS systes and assisted and in 4 pGer.
coordinating transfers of satorials between divisions 4
/(b", 9.{ k .-'
i other storerooms. Reorders of stock itses were also initi-3 h ' I ,Jg7h G ated by Power Stores. f 5g.J ;g.p, controlled , MAMS database onsitestock was itama was 3 The utilization of the Basic information on '
! :' by Power Stores.
available through that system which functioned on a B.aorder B l '- - In principle a ..; DY Foint/ Reorder Quantity (ROP /ROQ) concept. established f or each itemA f f .' maximum (MAX) inventory level was Y- to support plant needs without emeessive invento ry.
]
- r. ~
minimum level or ROP was also established sufficient time to order and receive repla cessents withoet which allowed j E' exhausting the inventory. Vben the stock level reached the -
- order could be placed for the DOQ to R0P (MIN) amount, an bring the inventory back to the MAX level. The MtJts system also contained data as to the date and amoaat of an item i withdrawn at that time, i . e . , a us a g e his to ry . !
and changes to the HAMS system The development, maintenance, and NUC FR are the re s ponsi-with inputs from Power Stores bility of the Meterials Management Se rvice s Staff (tfttsS) . I levels have been evaluated by the 2C133 1.n an
) The MAX-MIN to better utilize stock inventories, either increas-i attempt A basic problem faced by ,
g ing or decreasing as necessary. site personnel was caused when MMSS reduced stock levels
) Procurements through
! based on incomplete information. specific ites were not
'\ em-rgency and field purchases on a and therefore were not included in the MAMS usage b1 s to ry
/. included in the evaluation.
Both users of MAMS and F2tSS
.I personnel of fered explanations of why and how stock short-
.t '
ages of certain stems occurred. NSRS decided that asest- . N '
.taining the validity of the explanations would not be l I
ll -. . , fruitful, as Tower Stores and MMSS were well aware of the l'
] .
h p problem and appeared to be cooperating in establishing meaningful usage histories to base stock reductions and
) I Unfortuostely, the originators at BQ11 and BTW i increases on.
7
, y felt they were being hampered in their work by not having .j 4 [ , basic staterials available when needed. They considered MMSSA ;
)
h , the problem because MAX levels weren't high enough. h problem, resulting from the shortage of materials in stock I and the MAX level being too low, was identified at both ETH g j - [ and SQN and involved the boarding of materials. l In an atterpt to ensure adequ. ate supplies when needed, user j I < organizations would " buy out" certain itees as they arrived
- gl in the stochroom, thus forcing the reorder of that ites. ;
q g Power Stores personnel stated that on sees specific itema, j i dl, ne matter wbst the MAX level was, they coEld never keep J itema varied f rom usepe and clesa-4} , material la stock. Those j ', tal suyylles to plastic bottles and electrical eqsipeset.
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2.C .:: )o Ih i WP . . g ;g . K B ,. Q 1'm ... n l. ,l Power Stores is responsible for issuing material wbes of material.
- 2. '
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y},'[. requested and not for questioning the usage %s c .. .',/.fU'. t t
.i - l, V .j > 'Yp:p:.s'.:.V.h d.
N hoarding of materiale demonstrated thepersonnel and sodification frustrationandlevel 4,; i
'6..g.N /:dh'. f *
, . orperienced by maintenance in t.he procurement system. The j
U 7*
;j; '8[.IY,N;f,y hiTO;,\ their lack of confidenes discussed with Fower Stores personnel
-k boarding problem was described for better .: ,
h .?$.Qpf)3,$ at the central office. Plans were I , V' .:. . e- utilisation of the Power Stores Distribution J 7 of beavy use stock items.Centa Plans r in , g l
'. Chattanoose se a source I
W,[U',(b.
. . ': ,. , .. also included the establishment of the ETE warehouse as a JQ t
. ,i , .-
Power Stores Dietribution Center.
- Contained within the MAtiS syst em was the espability of PftSS ,
s' to monitor ato k levels at all Power Stores
.rg.. -l'h.[' ' ' in Chattanooga h locations and to automatically reorder tints also had mate rial as the the capability of th b,;. ',.g ' 'd reorder point was reached.
,' i M.: . combining orders of like materaal, but titSS personnel stated
$. j d . they were prohibited from using that f eature by OCC. The h gd}./l, -
reasoning behind that prohibition was not pursued, h. p op ; '), . ,' it Vbile the MAMS system has an automatic reorder feature, i h'!P -#$f.1
",p was not being utilized because the plant TQE was required by l Dh .' the OQAM to review and approve all procurements (both QA and j
, j.;." .
. non-QA).
Consequently, all inventory reorders were prepared by band and the combination of like orders by 12tSS was Rationale for not using the a utome t t e (b H performed by hand. the tim 13 system was not a QA rystes le .,- reorder system was that g' Tj;.y , and changes to the information within itMtS (material spect-
'T.>.( ) . fications, QA level, etc.) could be made without QA know-e &f '.,. ledge or approval. Inform.stion was provided RSES which
- 7. explained ef forts underway the to develop a procedure acerptable F J' MAMS system from unauthorized .
- !d ,' +- to QA which would protect e j , QA changes. NSRS bighly endorses that effort. 15pon coer- l
.( (, the MAMS system should be usable to !
3
; pletion of that larger extent, featurethus eliminating the considerable manpower Flt, . a requirements currently required to manually reorder inven-9 l J '";, ', toried material. '
9 M'
;.r..- ,
- 2. Power Stores Distribution Center f'$
t The review of the distribution center in Chattanooga and the ' d
;. i .
~...
y Investment Re cove ry Program (IRP) warehouse at ifTN was F ( % C."- , limited to discussions with Power Stores personnel. , M. 7 y.; u Fower Stores currently has a distribution center werebouse g'p i " im Chattanooga. At tbs time of this review over 100 itema # were being stocked there. The basic concept of that center R l "~.k a werebouse of inventoried itsee that the
' j.'
ves te provide plaats stockrooms could draw froe. Described plans included ' ft I C motstaining a 6-month supply of itame, thereby allowing the -?. c,f i g
- ytants te reduce la their coeceptinventory sadappea that idea associated eterage rs functiotally -'#
.c ,
requirements.
'.'e - e+end but will reteirs the coeperattee of all coeeermed to ?
m .:
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j b g
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.,. work within the systen. During this review, Power stores -
was having difficulty maintaining a stock of asops, for .
, , , , whenever a delivery was made to BFN to replenish their ;,
O%0 . . inventory, plant personnel would " buy out" the mops and ,
*:.c'
!!h.?D .;',M'f That process created a real shortage withis the g heard them. based upon a perceived ebortage by the 2t" @ '$'- Power 8 tores system .
- i. J 7- users.
w: . , ' ' ' g,:,'i.. The distribution center did notone have a QA program, but Power
. Ne i
' was being developed. At Stores personnel stated that only QA material stored at the 2
[.. the time of this review the center consisted of welding roit and dye penetrant. As Power
'.6- M([ Stores personnel were not ANSI N45.2.6 tratned receipt ,
77/ 'N inspectors, any quality materialtroe received at the center SQM to the coster to g
..f, g ir . ' required an TQE inspector to go
. perform the receipt inspection.
M,. ; '
, ).I 1 The IRP sesociated with TVA's canceled to thenuclear remainingplants pro-nuclear g
- j?'i vided a vast supply of materials of taking control
] i'M Power Stores was in the process of the HTN 1RP warehouse operation. It was described as l
plants. g-l
, f4
- containing s:steria l with an acquisition cost of ap rozi- 1 4 9*. mately 100 million dollars including approximately 33,000 I 40 percent of that material had QA '
r
@T N .'
valves. Approxleatelysuf ficient to support use in a QA system and documentation suitable for non-QA systems or
! ?,' ' the reasining 60 percent was distribution center, [
, -- 'E fossil plants. Like the Cha ttanoons j h.f.l~ Power Stores described plans to keep The the HTM iscility was HTM facility as a
- I s 3:[y distribution center for large items.
, also having QA and preventive maintenance procedures g,; d.-1,
..f. - prepared. >
~ .
I S'.],* f D. Central Office i
'f y M . 7 .. , The central office portion of the Nuclear procurement review primarily ,
, -W.'ft Central Of fice Quality
- involved the following aroups:
Amaurance Branch (NCO QEB),and NCOtheNaterials Materialstiana gement Section J - fianagement Ser-yl!,2. .ft 1'j - (MMS), Central Power Stores, 4 i'p% vices Staff of Operations Support. j j .d.
; The OQAM (Part III, Section 2.1) was the reference used to define lf TJ/;f the responsibilities that each of the above groups had in the Flowcharts which correspond to the OQAM-hl aR N. .-*[-
procure cnt cycle. defined responsibilities were f ound in DPM N72A14 Requisitions f* 3 for QA level I and II (Part 21 applicable) etsterisis andStores services q j I ' M:;;..%. , reviewed by various groups lee the NCO. Power and g 4 .3, were for loventory itees. 1eple- , fft:5 basically reviewed requisitions g j
- ., seestation of these documents was evaluated with only a few excep- p g ;
tiens to compliance identifsed. i
.[-[ :% It shoeld be acted that many of the NCO procurement responsibili-i 7*- ties and eseectated personnel had been transferred to the plant - '
$y se October 1, 1984, and the organisation reviewed by ItSES '
';. ', s it es As the taattieaa 1 wee the see is plers Prior to October 1,1984. ;
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-N Guy.:,'y :
.yf@.f 4 Gy;f' V IkY T.I,,[E)hM'; .n- ,g
. r. and responsibilities no longer exist at the NCO, en individual "
a,j* f.* . ; "49' ".-
' breakdown of each organisation and asseef sted problems will mot ._.; -
h h.fl. ' v, [ .*l,g sj be presented but an overall suminary is provided. .g
</b,1f,a;. '
7.rp Q,a :n ;A , _ .
'Procuremente of QA level I and II 10CTR Fart 21 aFplicable I d'
#~'. i 'materiale and services were circulated for review andgroup approval
,D" f $Y.' '!' *h/ ; The only with ' , [./.g
'h. $;' ,
. throughout the NCO groups identified above.
package was the NCO QEB.
, g, any visable impact upon a procurement of approval or acknowledgement ..g
~ ~ QV}:'fh(, .- " { .. Ot.ber groups provided signatures s.g I or vers within the distribution cycle due to the mandates of ,,
A "" N i t ' 9 * ' organisational coassunications. The value added to thefprocure- [.
- r , ; . 'p.',,r.d.' ' .
ment documents by Qga on the 21 procurements followed ross the hd** g! .' .t t.; v attes through the NCO was minimal. For the most part QEB changen
'.d (e.g., changing the y N.t. h/@l., 7 T,b s f,i .'
- were editorial rather than subs tant iveapplicable). Technical 't verbiage specifying 10CTR Fart 21 was Both
.,hgf,%
review of procurements were also being perf ormed try Q7.B. c ( rd ;,:., . the OQAM and DPH N72A14 specified it was to be performed by the q,3' 7 ^ . '. ~.
.v, NCO technical branches when required. NSRS found that the ted- tech- '
Nk~ ,nical branches who were previously performing most of the nical reviews were no longer doing so and it was being performed
.';'ef,*hf.h
- by an SC-2 sechanical engineer in QF.B. f
,y!] ,
J
., g~v = '
j' The responsibilities of the MMS were essentially clerical. They g'. , , ' - were to " coordinate central of fice NUC FR procurement communica-
, (.g~ ,,. tiene among the nuclear plants, Fower Stores, and the NCO."
K ' (0QAM Part III, Section 2.1, 2.2.1) They also performed a review d;;'iy,c-- of requisitions for " administrative correctness and complete- The d ness." (OQAM, PART III, Section 2.1 paragraph 3.1.2.10) ' T!.0, E review was similar to others perf ormed by the site and not con-
,W( - --
sidered necessary by NSRS. The HMS served as a paper coordinator 3, that moved QA levels 1 and 11 requisitions between Power 8 tores, NCO QEB, an1 the technical branches. Tilse had also been main-i.dr l . .
,toined on specific requisitions, but these files were not evolu-I , ~"
because,they were being transferred to the h'rh - ated for completeness The HMS also interf aced with other p ro curement
,g,M , '
.y plant sites.
The IQT tracking of available funds and groups on IQT contracts. g.<...,
/ administration of IQT contracts were functions still performed by .
the its af ter the October 1984 reorganization. l ;';iy ', Findings regarding length of time to prepare, review, and approve' >, S,44" procurements within FUC PR can be summarized as follows: O
*2 if ,'i.
{
- 1. Normal direct charge procurements took 4 days to prepare ,
e V- and approve at the sites anil 2 months to review and approve
- i ji l.h in the NCO.
l? $* . ds, ,, 1
- 2. E.mergency direct charge proc ures. nts took 4 days to prepare 2 Y-P and ePProve at the sites and 7 days to 1 month (15 days u
j 4' sverage) ,for the NCO to review and approve.
; M i- G.
, %. . . ,. . Emergency Requests for Delive ry took I day to prepare and 1
.., J. .
- 3. =
3 erprete easite and 8 to 14 days for the NCO to rirview and ,46
.: F
#lfl epyreve. .
3 ;V 3 94 - 3;; - g ,( > c
~ gy' 33
-l! s 4 .
%w.
I
- 4 4 g
/ , s w s problem knowing what a piping classification because the plant engineers don't classify their means on a snodifi-tation drawing in the P ant That problem results interpretation l way as OE. j
;. systems the snee
' L engineer having to communicate with OE for an
$ ,) before material is bought so the appropriate material specifica- ,
"j ' . ,
tiors can be placed upon the item procured. was identified in f OE precurements , one good practice ( Regarding an IQT contreet could laborious be and review issued that Requests for Delivery on fh. which i Q c
' directly free Og without going through the approval process employed by NUC FR.
Another practice, f questionable validt-h[. 0- m' will be discussed f urther in section V.ts, o assembled f ree Vbere a large component was AR5I 545.2 QA 4b ' !N., / < ty'was identified. F c .. ( b coemercist grade parts (parts not requiring an an 11 enviroessent, v
'[g,'* ,
-i proarse over manuf acturing) and qualif Led to hI h 0E continues to procure replacement parts as commercial grade i
,.e -
assw.es the component maintained its IF. classificat on.
.,m, identified is the areas for isrprovement specific to OE were i 9, . '
\O
' ] ,, f h. Nolimited areas reviewed.
fil
;h T. Purebasing f ,
FURCH involved gaining as understanding i .. The review time spent in identifyima the
.? ,
of the laws pertaining to Federal procurements,and their specific prob-(PA) responsibilities. ! g-
- . purchasing agents'less within andthe procurement award of contract.cycle, Specificand a racking specific re f tions through the bid process revneved or evaluated due to i
,. ,-.- internal FURCH procedures were notThe pas appeared conscientous and professional
' iS* C time constraints.
.-( in the performance of their responsibilities and demonstrated a p @h. ,
a willingness to help in improving the procurement systme. They . f j p.g concern over the excessive use of emer-r, j eepsistently expressedsency The purchases and unrealistic "want" dates an f '. TVjcredibilitywithvendors. found in requist-be technically accurate on all specifications
% s tions.
In the PA's opinion, too and many specification not within problems the TVA review were cycle. l l being identified by vendors
, .( One review area involved obtaining general understanding of the a procurements. Many were
] Federsi C , legal constraints placed on and EE0 and small business require-identified including low bid including their impact upon ments. Many of these requirements, k to site
) the procurement process such as time delays, were un of .nownA relatively ne
, technical and NCO personnel. that procurements Law 98-72 and the associated requirementCoasmerce in the Business Daily
$10,000 and over be advertised were known by site personnel and pre-ssed during prior to the bid process l seated more corsternation than any of the others discuinterested vendors the equal ,
I , this review. That law allows all bid opening up to AS '
- 1 opportueety to bid on en item and to the dessys great numbe r o f itees required ;
, ~ days, ilatortunately, due Busjny Daily by all Federal to be advertised in the Coomerce l
( Te a i
i
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.N NN M l N o
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6 , ' U WM R g lMQ NpWNW ~ m $$$ljp% f m m m en MSW M __ h 5 1 i 04 @ l Ekk.M , . pf Off JJd i mPU
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[n airafecess[e djdiey$ests ay' f $ L 081 Treason t8 erpect thEti ItiK
'. i .4, ~., factored into the ordering lead times'becswa ne' , v., g (' 'J g . delay would be other tiene delay had been f actored in either by the origiastor er -
,,,...c,...
? . ,7. "', anyone else in the procurement process.
g}']. A consistent problem identified by the PAa was the neoant of time
- J -
taken in the resolution of problems identified on a requisitios
? The FA did
, "Dd exceptions taken by vendors when submitting, bida. In fact, the FA not comununica te directly with the originator. The signature of ,1 2 r typically did not know vbo the originator was.Therefore, the FA had j, the originator was not on the requisition. ;
to rely on soecone elee (possibly irom power Stores resolutloo of or Prob- the ' Materiale Unit onsite or NCO) to coordinate -l less identified with the requisition after the bida vers , j e received. The agenta varied as to the method used in the a coordination process although all were aware of the resultaat time delay.
; l Another problem identified by the pas was the time The delay review"involved per- ;
in getting bids approved by the NCO QA Staf f. contract are takes) formed by NCO QA (when no exceptions to the on a list of
$ consisted of stating which of the low bidders Thewere p roce s s of IMECI vendors with a TVA-approved QA program.
sending the bids for review was estremely cumbersome and time j consuming. PURCH sent the bid to hanagement Services, wbo sent After approval It to listerials Management, who sent it to QA.involved, QA would ,
, the process was reversed. If an exception was send the exception to the site and coordinate approval betwees , '
TQE, Materiale Unit, and originator as necessarT. g l
! The t isse delay resulting from the eemorandtses and paperwork
- generated in stating which of the lowest bidders had e TVA-approved program was considered excessive and unnecessary by NSRS.
In many cases the PA had worked consistently with a parti-cular commodity and was knowledgeable of the approved vendors. To eliminate time delays and excess written coseunication, it would appear prudent to establish guidelines to allow pas the p task of selecting the lowest bidder from the approved vendors i list. That responsibility would be applicable for cases only in i which no exception was taken by the vendor. E , The ITRCE portion of the review occurred a f ew days prior to the October I, 1984 transfer of NCO procurement responsibility inf ormation concerning to the the
- sites. The FAs bad limited or no chsages which would af f ect the procurement cycle. Although some ',
i Lies is required in a transition stage to incorporate changes, ceasidered tble symptomatic of what appeared to the sevsew team 7 . be limited commmunic a t s ee occurring between IrVC T1 and FUNCE. W I .4 i __m .[ l
) (
v a *
. . . E. .. .
.hh ye.
s b p' Ri . '.;* t : .. 3 M7,%w , , O. Qua Mty Assurance J ;g 14 s. t-
- f.
li )
',p':g T
.: i ,". * .
.y * ,~Pending Thp NRC regulations and TVA procedure recognize that basic couro-ats een have varying degrees . cf quality plated upon them upon their importance .to safety. The OQAM establishes de-fy
,d y t ' ff . -four QA levels (level I, II, III, and IV) to which items or .
s e rvice s for CSSC may be assigned. Guidelines in assigning l n:
':',?' j
.. levels are listed in paragraph 3.2.5.2 and are identical to tho**
..~ g listed in ANSI N45.2-1971. These are inte rpre ted by N to .,
range from items requiring considerable QA activities to those
.'I*
requiring little or no QA, i.e., co==ercial grade items of stand-ard design which have proven successful for many years. In .J - g,1 - reviewing the QA levels in OQAM, Part III, section 2.1, paragraph , M r .d '. . . 3.2.5.2, it is found that each apply to CSSC with QA level I , r y n /, a pN,;.. basically applying to, among other thinas, ASMK Code meterial and , items procured to a standard unique to the nuclear industry and decreasing in safety importance to QA level IV with no saf ety-
.- . related function.
~
Reviewing the definitions contained wit hin 10CTR21, 10CTR50, and
,, associated appendices, regulatory guides, and the OQAM, it was
.* clear that TVA has equated the following tarmat k
i 1. Basic component.
- 2. Critical - *ees. structures and components (CSSC).
2 3. Structures, systems and coeponects important to safety. T
- 4. Safety-related structures, systema and componenta.
l I Those definitions being equivalent are used throughout the OQAH in a variety of contexts and introduce conflict and confusion. [- ( A contradiction is introduced in the description of QA levels III fC f ! - and IV. In the OQAM both levels III and IV are described as j 5
** being for CSSC items. but elsewhere the OQAM specifies that l "-
' levels 111 and IV are not for basic components.
4,. ; I *
) :i :
l 'v;i ' .' The use of cessnercial grade items in association with QA levels h b presented confusion and contradiction. Commercial grade itene were allowed to be purchase.1 by the OQAM, Part III, Section 2.1, l .
]i f) I' '
l ('M peregraph 3.2.5.2 with QA levela I through IV. However, OQAM, 1 pl .@4 *.. Part 111, Section 2.1, paragraphs 4.3.1.7 and 4.5, escluded level J I l ; ; .- II as an option for purchasing commercial grade itema. In addi-1 %,, : i l y,-. : - tien the OQAM, Part 111. Section 2.1, Appendix F, paragraph 2.2, , stated cosanercial grade items were not basic components.
'M Mf Items procured with quality level I and II designations require V* i-considerable documented quality control unless procured as coe-l jN .,. .
i ( ". mercial grade. A commercial grade quality level I or II procure-
.~
- mest could be from vendors with an unapproved QA pregree, require 4 wj; me documented quality assurance, and receipt inspected by Power 8 tores persecael. Although allowed by the OQAM most but not all
)
l { r ,. precurseents of QA level I and II commercial grade iteme seen by
-f 55BS were required to be troe vendors with N45.1 approved
'( .'
.{
!]4 i Fregrams, j l { .E.i - '
n p, ; .. l u . 3k4 l h
I w
) J l
j JJJQ Uh ' .c
&s..f?iW,Ndw .-;(u. .'
I y .
- .9 -
1 2..y[h' ! 37 , l i&*QY f -j all essentially tbc same for coe-As the QA requirseeste are I N@j.:- p eertiel grade items, M8Rs believes there is a is11acy la trying -
.T ,v. ~ ,
t* Piseenhole purchased commercial grade itema inte a variety of d3 E .J,- QA levels. The origin of this f allacy appeared to stem f rom the l t " application of 10CTR21 to items procured to either QA level I or W f }W$!!.F ' i if)G 1 TVA, in the OQAM, stated that the determination of Part 21
, I II.
%IU -
h applicability applied only to QA level I and II procuressents. y K ,'l, Determination of Part 21 applicability was contained within OQAM, y Myg,i Part III. Section 2.1, Appendiz T. In order f or Part 21 to te d ycg 4,;. .. . determined not applicable, the item being purchased usuat have been a coer.ercial grade itee, must not have been a completa basic (* c. , coeponent, or several other criteria. Appendix F. Attachsuant 1, was a form, " Determination of Part 21 Applicability," which wt.en
'.p-i ' ;'
. # completed became a QA document. The first question asked was "is
.. . the iten 'coassercial grade' (yes or nol. . ." I f the answe r wa s
'- U Yes, Part 21 was not applicable and any remainins questions P -
, remained unanswered, such as, could its failure canae a basic {
component not to perform its required safety function. NUC PR QA Personnel agreed this was a probien. Considering whetber or not a commercial grade item could effect the ability of a basic component to perform its safety functice In its c :' was addressed by the NRC when Part 21 was developed. i f first publication of Part 21 as a proposed rule on March 3,1975, the wording was such that Part 21 rould be considered applicable In response to inquiries and to of f-the-shelf or catalog items. public meetings, FRC amended Part 21 on October 19, 1978, and F recognized that connercial grade items could be purchased without
,~
the Part 21 requirement to report defects and the associated liabilities for not reporting them. This recognized that comuser-
.3 ciel grade items could be purchased for use as a basic component
% l - and Part 21 would become applicable after " dedication" of the
, , ;, , part as a basic component. Based on discussions with TVA Office '
n , . of the General Counsel (OCC), this dedication means to put into R.
' use and at that time Part 21 reporting requirements becomes the I
responsibility of TVA. Consequently, the NRC has allowed the use of' items with a variety of QA levels including commercial grade ! f' l as basic components. However, the use of commercial grade items
.l I
- b. with Part 21 not applicable does not eliminate the need for some 1~ level of quality, rather it shif ts the burden of assuring quality and the continued ability of that item to perf ors its safety function free a joint manufacturer /TVA responsibility to TVA's i.
J ' sole responsibility. That is, if TVA procures a commercial grade 3 ites for use as a basic component, it raust either assure quality f l ., during the manuf acturing or through receipt inspection, testing,
& j a ,
or other means. For a true commercial grade ites that is pur-i
} chased of f the shelf by part number with no documented quality, 5
the only avenue available to TVA to assure quality is through e l' j ' receipt inspection and testing. l Is 00AM, Part 111, Section 2.1, Appendiz T (2.3.1) the statenest / is mode, " Specific components, systems, and structures listed oe the CSSC list are basic components by definition maless pr+ cured
. f es commercial grade." Thorste lirs the fallsey. A besit coe-1
l
- t y
'~ -
_:'Y &WNGRMTaMi5hM.GrM12H bYEE? swr .
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'N . h. hM7,4,.,. it af replaced ,
.W. ...
; ..w s. - a basic ceaposent 'vbetber or not " p;.. ,
' .r-ponent ressins vith a pedigreed item or commercial grade itse.
{,j ,.,3 1f.p'{d.'I/. j ( ,, item is y " j'*. c. Part 21 specifies [21.3(a)(4)] that "a conseercist grade It does
*Ekf.k. -
act a part of a b5 sic component until after to dedication."be a basic couponent
.he$y" . not state that a basic component ceases A commercial grade itse - Qllj can be ff ;,
W'y:! .{ - if supplied as a commercial grade ites.can be used as a basic :y' compon
* ** ! used where its failure could cause a All basic thecomponent Part 21 applica- not to .
D'f rit - perform its required safety function. f., commercial grade item is if TVA finds it 58)M , .$'6M.': ' bility means some for a point in time, TVA must report the defect to f' defective at J.}
. .,h .. ,,;'.q, $y. NRC just as the vendor or TVA would have to do if a defect were y
h v. found on an ites where TVA imposed Part 21 upon a mnuf acturer. 9 bgll.i~., criterion for judging [ $
- y. In determining Part 21 applicability one i a;
l*, A .' Part 21 not applicable is by identif ying the item as a commercial . p?
- g. *. - grade item.
Host Part 21 not applicable determinations seen '[
- . during this review were because the item was identified as being 7 f.
).; coernercial grade. That determinationhilniMoq_of has resulted in what NSES coueertial 7" concludes as a misapplication of the ,
t' W ~ grade. One exsipi N ffered in s% port of that conclusiole t ' SQN was written to procure Requisition number 951134 from t *
?
sheetmetal for The metal was to be manuf actured ECN 2768. and required the manuf acture r, to ASE necifications a , through Appendix E Attachment 8, to have a quality assurance The
>. met the requirements of ANSI N45.2-1971.
i program that I }i '. items being procured were cleasified as commercial grada and V.> assigned a QA level I Part 21 not applicable. J .: ,,, 3 i E.'5 , material to an ASTM Standard and requtring an ' ^. t i Purchasing that is certainly more restrictive and prescriptive
;j ,.t.l . ,."
N45.2 QA program It therefore should than purchasing an item to-a catalog number. J f r. - I not be classified as cosnercial grade. Part 21 as may still notnot it would be l g " ,. ,
! applicable, but for different reasons such l 1'Q*,* adversely affect the performance of a safety function.
F It appears that a situation occurred where material was being , I
'.[ y procured not for a basic courponent Asbut the for an application Appendix F Part 21,that
/(- still required QA level I attention. questioned whether or not it is cosener- - 1 form first form were N. applicabilityit cial grade, appeared that personnel completing the {
, a taking the easy way of determining Part 21 not applicable by j h *. calling it commercial grade thereby avoiding the evaluation of i .. other significant qualifying factors. ll.
~d #
. g.. It could be argued that it makes no difference if Part 21 is ,
r; . declared not applicable by either calling the item commercial
- j is not a basic corpooent. The argument grade er by deciding it J.
as stated previously It is recog-however, when, p of commercial grade itana retsires breaks dews, , q y aimed that the mesof acturing dy , me .g . vd Q4 program er TIN receipt inspection dile other r .
*.b g.3 jsv. !
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i I )
. I
}h.'..-X " hd '%.$.j,TU p l ,
't.
' 'd; '
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- A. .
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nee-CSSC itene may require eensiderable QA with apprevsd eeeeeenst pre-purchaos /
@h&jhh., N .Alf ?
- grees. Aa emasete of a determined seabasic N * 'with toeflictima Part 21 determinations is as follows:
I f M u.,y,%,;. hh'2h, ' N. -
~
nequisition number 343910 f ree Sqr was written Specific to procure ietfermation was j .'O '; rsector coolant
~
pump seal parts. n '"Sl,W$ h . ' ,
,ptwvided es the Westinghouse pump and the parts were y .
y hff7$'J S ' #. ' required to be manuf actured in accordance with the original
.W f y / 4.:.p.~.
' requirements of the Westinghouse g-specification 677355.
, ?:
The plant TQg staff crisinally classified the procurement as i @!.,dv4[ l I' Y- N, QA level II, Part 21 applicable, but NCO revised the pro-l , as .(.L' f.k - curement to be QA level II, Part 21 not applicable because ',. F < . . f/. . i they were not on the CSSC list and would not affect Considering that the the .) f hi'h-[W'. - Q@MhMl.t F M D safety function of a basic component. seals was developed by the manu-specification used for the (Westinghouse) of the siain coolant pump, it could MM'f. v.iy i' . '. facturer to the nuclear industry. Aa 5! II ' \/ l well be a specification uniqueshould probably have been identified such, the procurement 3 )).fI . .",7 '. an a basic component and de signa ted Pa rt 21 applicable. gf,i ; .. ' When Vestingbouse supplied the parts they included the Part ' sa 7;i. "- ' 21 applicability. M. c. ~ cousse rcial
.':vc In other cases the use of a QA level I or II for a
'/.'.' srade item may be inappropriate and imply a level of quality that
. ',/[ ' ,
is just not present. For example: 2 k Requisition number 932925 from BTX was written to procure a I ['
- It was ordered by the mann-selector switch for ECH I.2115.assigned a QA IcTel II, and it M. facturer part number, it was
.Y g required a packing slip for documentation.
gg j.7 a it saa purchased from a supply house with no unique (M re-
.cf r.
(.-! F.. . g quirement or nuclear standards, it is considered by11NSR$ to truly - t/p) 6 I ,be a commercial grade item. As such the QA level is con-sidered artificially high issplying gus tity that may not be fac-c q-o
'y' ' Itual. That switch was to be u%1a .m.. panel that was qualified.
J
-;k along with that model_ewitrQ t ~~'ategory TVA,.lo IE requirements. It of coesmercial grade
[' .y. - jg. ' *. theref ore ~Elearly falle %2 tt c ( items dedicated as a b'al. . .apr . st. j [ i DE has made a decision regardit.g commercial grade 1E equipment. ' j , E Basically stated, if a component is assembled with consercial f, h grade items (such as a motor control center) and that coeponent T .* 4 c If * ' . , , is physically tested to 1E requirements and is qualified, then > l $.- the qualification of that component will remain if replacement [ ,f- perta are the same (same stock number) or equal. l 9 Even though counsrcial grade items are allowed to be used as - besic composents, in doing so TVA assumes added responsibilities
- j. v4Lich it is not adequately fulfilling. Recossising, for example, f ik p
that TTA had qualified, at mees point in time, a commeercial grote ' item ser use as a basic component or a part of a basic Mmt, 1TA currently has me program to assure that intura g e3msesta d.'- 3* 7 - w MU'
's .
9. l
m Agg . I :.
.- ' L ; AC ,4. :.JQn i'
~~
, k'h,; .h' W- T.
I
. V;, '%. . ..., the esse as'the one qualified, and there no C y. win la fact be esect1 Rication. If a time conse r'cTal srede }
- A r-
*E
% k,$glLa. Ml'c.En
'9 A' ' 'lere matatein th W ~uirt must>er Tr'oe a meauf acturer or sirryller, oved 3
~ ~
'"11 C e purchW H'the massf acturer or supplier is not . required to have, an sFPrthe itse to
'h!.frfEh
-Q'f/, hl.O.
' . QA progree, and TVA only receipt inspectsThere was no testing or inspectice
]
j
' the part number.is correct. item would Perform '
I g f. i ,, d 4
* 'by TVA identified that would assure thatto the the item occurred er ;
l p.%.$ as required or that detrimental changes functional test of ***1y .J NUC PR does perform a assurance that it did not occur. h,..,y.,,. .N 94 ',. ~ . . '} installed equipesnt which should provide seesThat test, however, will ch.*D' "J "- will perform during routine operations.the item will Perform as required 0 ,Mb yyi, dhy./l not provide any assurance thatTht_stanuf acturerA_oLeosinW ah t ea. gradt / d' i 2 2,$$,l? under accident conditions.are under no obligation or authority tg._ identify c ,jang f .M itene TSRS was informed that ch Eges gene That,Mhowever, y E s accompaniee is by Va j y W[QV(Mp,Yr i.' h[ part number change by the manuf acturer. Additionally, what would q
, lh G,n.] . convention rather than by requirement.
.j d C' constitute a change would probably differ from manuf different acturer to labri-l.
l N%,$ $ 7,@$f'* .L - l
'g manuf cant acturer, and a change as subtle an using a(which could have a v
, jf.h . ' U , conditions) would probably not be considered a change try any j N Y,V u
{ 5
) ' manufacturer.
some manuf acturers will not I , interviewed stated thatnuclear plant. OE pe rs ommel j[
.(,5k,'*J. h , D OE personnel sell courie r c i al grade items to e i
,j i'i w h received an order f or a to SQE, they stated that if certain manufacturers it wee to go, e.g.,
,.- commercial gr ade part and knew f
9' . would automatically provide the QA documentation while assembling the on the itas, domta= delay shipment about six months {
; h?. ,, : 4 Mion, and would charge ten timesgrade.
were commercial the amount OE statedthey no valuewould charge T [ for
.I " '
M \the same added ites if itpart, it has not manufactured any differently to the . and TVA already had the iten so
!. $w.a sthan the coannercial grade ites, -
[ o ,,1 ,
.a defect were found TVA would receive its 10CTR To avoidFort what21 notification on the previous e r original orders.
pricing, an ordering procedure was
-"'-r0E considered exorbitant
, f p. ,,
!* * ,,- ' rom certain manuf acturers where the 3 /,g' l devised when ordering par . r was the recipient of the conser- ;
J d '
- on
* :8 Power ciel grade Stores item.Distribution CesSpecific Inatructions were provided to PtRCH IL l j .
to mention 10CTR Part 21, 11 quati- -
- ! ? ,, .
the Purchese Requisition not At the time the Purchase Requisition
- j ;
IN*
" fication, or nuclear plant. f d y 4
g I . was prepared, a Transf er RegiIsition was prepared for the u . That Transfer Requisition changed the classification of the $
*l
) .
commercial grade iten to a QA item and directed shipment to the .d
- f .0.:. . appropriate nuclear plant.
. . I'i, i j ,
i
!.'<. That procedure had been reviewed and approved by both OGC and I
c Discussions with Division of Quality Assurance, Procurement I g '"~ 2 OQA. Branch, personnel revealed that the manuf acturer in 4 / s
; 5 Evaluation
] [ geestice did, according to OQA audits, have different production 1%g i [ [, runs and QA requirements for items going to nuclear planta; il .
, I .[ therefore, it appears that some value was added to the commert a ,
h, grade item f ar the increased fee. i
- g. )
3 u z t 9 [# e' . I
s' } 1 s .,
- 9
- q. r. .~,.; a j' .
. f. Q'.!%
44.,,Y,": ,
> f*y l) .. .'.....ls. ;, (- a part of ,
.z: , - - - This entire pestica was met pursued any further regarding as this y ,
h' ' , .N, >
' this eggiew.
NgJta has serious reservationstil it can be evala.ated [
% -.s W . ptatties and reserves final judgement un1)nt11 that time it would be considere J
h gi,'!G.
- Nd" *
!b* farther.
parts of OL and .NUC PR P13 to evaluate pg. mvrN'.'.F.,. c - 1 ****- b the ) conflicts, confusion, and fallacy described j h..hb< i. system a ove, is being
-l w . ~ . . With the QA level use of '
l y. sitsetion has developed whers theI and II, through the levels N, Mb,'c,. - In h4* F[f.' % .' l ' further divided Part 21 applicobility, to accommodate coasmarcial grade items. within the l grade - MT dolca so en artificial QA level is implied for a commmercia i .. ites (i . e . ', commercial grade itee ipurchased tely purchasedwith no QA and - f I O kh[/c' h fr W, L* c ." ,
'!.* . W.
assigned a QA level af I or II), or itema appropr a i l grade. It if the r 7- with a QA level and requirements theyare are, called either commerc ais conside l p h,lj.., consercial grade itesa are recognized for what level I ard II
;- of QA
.Fg '. QA level IV or non-QA, and procurement In addition, all QA IN .79 commercial grade itema should be prohibited.
- 7, level I and II itesa regsrdless of the Part 21 yurther, theapplicability quality
,y,g.{i.
- r. should be receipt inspected by an TQE.
item adequately performing or c.c,m requirements associated with from the Part 21 h '. . f. , ,' affecting a safety function need towhich be separated has nothLng to doitee's with
< . . .'1 counercial grade determination ^
quality. Whether thefunction qualityisassuring activities to the for required anjointly shared by the manuf a M'.",;p
'ijt . ,,N s t - ability to perform solely a by TVA, la irrelevant
.f. p' turer and TVA or 4.jQ, quality activities.
h nf;,; basic philosophical problem with the QA progree forpurchased as
..s There is a versus itema items purchased as basic components n
y l,f. TVA's
\
dedicated as a basic component.
,2, f .
commercial grade but for basic components is based upon adding ~ 3 y**c;. -
procurement QA program activities where there s and is i f, ':y!"' additional TVA quality assurance d ,' '3El, 8 Iquality assurance to begin with in verifiable the manuf quality acturing in theproces 3 * -
!have no quality where there is no f . j h.. .^', -
aLanufacturing process. e ,rl I
~ responsibility when using commercial grads items echanism to To as basic fulfillcomponents its , TVA vf H have to develop some mitems in- such as a receipt f
qualify replacement commercial gradeis more stringent than what is that inspection.
, b ,". ~ spection and testing prograra in J.
gj' 5 - currently in place for QA itees requiring TQE receipt (yor e M ., see section V.B.5.) the
} ! $y the QA progras associated with procurement,
?
3
- Vith regard to and sometimes contradictory, 10CTR21 '
incorrectly es a determinant in
/
E OQAM was found cumbersome jf ' 11cability was being used y establishing quality levels, and erP the Appendix T, Attachment was inappropriate and being f 1 3 form, for 10CTR21 applicability b.einggives/ ., alessed. In addition, commercial grade iteme were had 3
} implied quality by assigning a quality level t
.,,- usedto as them, a basic and TVA; a commercial grade iten ident tea 41 stem, f
l 3{;'d se mecheales to assste
. % ._ rt wes14 function when needed during act '
,, ,,p,.
43
, m.
; , rf )^
.2 :
+i .Sl.~ * . m._..
l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _
! . i ,
/ >. . v
_( l f h I l . ~ I. FUC Pt Ft,curement Prebles Task Force -
* ,'c, <.
interviewed two gain of the three-member NUC FI . . ,
'q :. Y <
The geview tass to an understanding of the A .. . . . . The task force
' . Proturement Frobles Task Force .,.
, ' ' pertelve4 probleme within the procurement b Darlingsystem.uently (Loo 640810 on August
.~"
10, l l k.
- - h' .M"M...$ ;
y r n '*%g,v ' . .
.reprt and recessnesdations il ls4 in a report free Eric Kvaven to Jim were issued su seqreviewed The major recomsmends-
$lUY ' ~ ~ 294). That report was ,
fi ' '. !U .' . assimilated during the procurement review. tieaa identified in the tianagement Sussmary of the task force
'g-l,jd,, Ye/['E; report were tot ,
gy;.;,{,.!:;? . Establish an adequate planning group at the plant. (1) k'af[h 99 r n , .zhe. :- (2) Implement status tracking systems. h(, Set goals for turnaround time for each review /spproval j .gE . : %?t,~ s: '... (3)
.Siy,V ' cycle step.
gig,T;.' .- for expediting efforts. (4) leprove and add adequate resources g Improve coansunication between FURCH and the sita. (5) i the procurement cycle q/ r. . (6) Eliminate all unnecessary steps ini f any, steps between the h.h:?, with the goal of placing very few,
. ,p requisitioner and the purchasing agent.
f .L..
.',a,.
p f Improve the inventory stock out problem. (7) i' $3.11 .
, Ifu d .9'" (8) Better utilize the automated systems.
Kl
~ ... (9) Develop improved QA procedures and training. -
$ ./
6: ...(10) Redefine QA responsibilities for procurement.
)
f 9yr. 'r g made concerning the ' proposed 1 i lj;
,' lThe following observations were recessendations:
$ f ,[ .' ;
I ,
. .: (a) Items 1 through 5 above have a basic emphasis and designated contacts for FURCH and
~
czpeditors, trackers, The basic premise is to eliminate the delays. {*s OE should interface. be emphasized though that time delays ite Theatonly the s review team. ! It
. .p. could not be substantiated by theinvolved procurements which traveled 3 6 consistent time delays Those time delays stemmed f ree i
i. , ..
through the Central Office. requisition received traveling l f il the amount of handling a between the Haterials Management Unit, NCO QA, Power Stores. was elimi-(f @j ;' iff55, and FURCH. The Central Of fice QA review each s nated in October with all reviews now performed at 5 g 4; Adding more resources to the cycle to per f o rm the j I :- d' site. recommended innetions will not eliminate l a basic cyc e.in problem of too many people already in the procurseest
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U t 1 h b b . 1 y N Ahbeweh sary stept la (Lesthe 6 receemends procurement cycle. thetbsellainatten steps aretheactof all euteeres-N f . . reedily identified in the report. It appears that r , satensive tretking proposed would be established to fo11ov aThe tracking would s l:. g .: , M 9,i*jf.,.j . f. P
' .c7tte similar to what presently esista. request and be main- =
O' oo pparently Start .with the procurementset received, aside, and finally ;9; k
,'N*.,'l, ',
h]^k:- JO. i teined Some until tracking the item is may be appropriate and effective, but k
*
- A' maed. find the people who are not p'
'the emphaste appears to be to Instead of developing a performing their job properly. reviews, more emphasis is needed in '
.? " i " ' ' -
method to track all the i.e., identifying the ',.
- N' simplif yin g the present system, f .
g ( D.N Da~ reviews resource peoplenot neededpresentlyand betterwithin available ut111:stion the system. or elimination
.j W o f -
review.
~
f
)f f. . . s 'r',
(c) Hecessary action on item 7 was observed during theproblem, more emphasis 1f.M., . It:58 and 2 i To alleviate the stock out T. 4 *
- placed on having accurate ussge history available.An additional Power Ston es were coordinatinr. that effort.
) h;p,f kl. ,-
~ Task Force report recommendati.m to alleviate the stock owt
%V was the increased us . ige of IQT contracts. ISRS e!
kg "..il- d problem no benefit in observed, under the current NUC FR system. the ID on am 107 ' " 1 : .ci ,: using IQTs to reduce time delays due to i.e., going through the
%;A,.
; '- being treated as a new contract,
.t'. same review cycle every time an RD la to be used. A defi-nite benefit can be realized if NUC FR uses the Iqis sa Another
[f! .. , f intended and prescribed in the Procurement tiaanal.
!% improvement can be made if site Power Stores order parta as and not save them up for a big order.
7 f.)(..l
- 3. 3 7; -
inventories become low Y 04 .. f (d) Item 8 is' highly supported, and establishing a uniform I database with f orQA control could enable the useboth of the QAauto-f:h V /.';n I'.. reordering of all inventory items ' h
- t. mated system
);f %. This would be an effective method to eliminate f 3
and non-QA. review performed on an item each time f p.f
,'.,v '.l ; i
' the unnecessary siteCurrent emphasis by HMS, Power Stores, and d t it is reordered. .
j <?.:-: / - l NUC FR should remain on QA program development. ~
; -[.Y. .p '
(e) Although iten 9 and 10 appear to be directed toward QA, the ( p 'v'r::
- train all personnel in the a report substantiates the need to j r.h. ' < procurement chain and to revise and standardize all proced- t.
; s :7 utes.
NSRS fully agrees with this recommendation.
;s. . :, real prom en areas in the
E The Task Torce report identifies some Immedi-i ,i, procurement cycle and makes many valid recoemae fstions.the more simplified ,
solutions j ste emphasis should be placed on y
, like eliminating unnecessary steps that could provide significantAn 7NSRS suggested -
j '. improvements in the present system.is presente,1 in Attachment 1. ' y .
, to the problems with procurement . .
9 3
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- n. gI Ptances L outACTED J J.3. 'e d 1 h:d:s.(&"'-)'.Yl 1. ..
' A. . arme terry het.se Piant g
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*: I: C:f?:y n;">J;;hja'."- """"""** $1. 3 j
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-t R. Cole T. D. Cosby OQA3 Head Elsetrical Maintenance Group
,..',f
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g w$e.p4 9 ; i P.t t ^ p ,, son t Sosevisor, mt.uais uut Quality Assurance Engineer yisf.U g . . ' .. - O T' '8 Plant Manager h. d'g
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H C* R. E. habry Chemical Engineer Materials Of ficer, Power Stores j *-: l h'ef 1.d ,.. J ' - D. C. Mine Head, Engineering Group . ,- , .- , ~ 7: ;t , J. R. Nebrig Supervisor, Modifications Section . c,
$ gJ '(2 .. 's; . J. C. Owen Materials Officer, Power Stores
p f; V. J. Percle Supervinor, 1.lectrical Section ;' y %E.' J
}
,[90ij[.g[v.
.$ Ut; ~ .; J . R. Pittman Asnistant Plant Manager, Maintenance Asnistant Supervlsor, Power Stores R. D. Putman di f? *>. . f. ' . ' S. W. Solley Elv etrical Engineer Electrical Maintenance '
.k.'. ' ' ~ , - V. C. Thomison Supervisor, Engineering r[;.
' M4 j'" j ..
V. M. Vargas Specifications Engineer, Support Services i C. C. Vages Head, Mechanical Maintenance
.g Supervisor, Power Stores h.
B.11. Weeks 9 u@ [ . T. P. Ziegler Branch Chief, Site Servites ' l.r,y; Materials Of ficer, Power Stores
,,'Q.} . '- - V. P. Zinuerman $y i em ;.i B. Sequoyah Nuclear Plant l g,
~ 7. .o . Supervisor, Mechanical Modification l
h* f. i..D. Alexander Section Supervisor, Compliance Staf f R. E. Alsup.' l ')3.' ' C. E. Brannon Supervisor, Power Stores a * .'/ ' , . T. L. Burke Mechanical Engineer 9 l
'.H '
S. Butler Acting Supervisor, Pield Quality Engineering ,
't M. , "'
- M. L. Campbell Mechanical Engineer Mechanical Engineering Unit ll l
' 'r t S. B. Campbell Materials Officer Power Stores 1 -, f.. ' ,* M. L. Crane Unit Supervisor, Materials Unit, Tield Services M. D. Ebel Materials Clerk, Power Stores R. W. Tortenberry Supervisor, Engineering i .'C L. J. Treeland Material Officer, Power Stores
{ I - Supervisor, Field Quality Engineering f J. R. Hamilton - i Mechanical Engineer b.. P. H. Hitchcock Electrical Engineer B. A. Einsey j
' k '.>.
3
.;,, j!, D. L. Love Supervisor, Hechanical Maintenance Engineering Section lj :'
< ; C. W. Petty Material Officer 3'
p J. Robinson Group Head, Modifications Supervisor, Power Stores f i i J 'f ', J. R. Staley C. R. Stuta Quality Assurance Engineer, TQE [ 1 S. W. Vickory. Material Officer, Materials Unit g -[ l f . , tr. - P. 1. Vallace F1 sat lianager e
)
R 1 lI ' ( I,8( , I .e> AS 9 l l . I
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! .t,5 .!.;m!N; nth . .
- "MI C. Centeat office ,
g p$0Q.nj;'.q $.M.N
; ~' .
1 D. A. Carter Material Of ficer, Materials Managensat
- .di'/,1.j,b t. , .
. R. Favreau Mechanical Engineer 8
'#L,.3;;7e:4.. R. D. Ricks l .,
It';;4p.:. :; . , Materials Officer, Materials h angement 1 ; i ,
,J. Hood Supervisor, Nuclear Power Stores i I
. M '
y h a.hp,'.ji~.* W' ' . I
- A
- Jew. ell M. D. Ee11e7 Assistant Supervisor, Power Stores Chemical Engineer g/pt.T.j,yj. .;.: I J. E. Law Branch Chief, Quality Bystema
. 'W.d;ir < gs ,
T. H. Lewis Supervisor, Quality Assurance : J. W. Habee Head, External supplier Evaluation Group ..' y.g{j;',yp;< .. v-; ;.J., d . ield Supervisor, Power Stores ((' $@(1,'gy . , Supervisor, tiateriais fianagement .-
><.m. s .g ' .
R. J. Mullin Director Division of Quality Assurance i. l ; .; ."- - D. C. Howading Breach Chief, tieterials fianagement Services J j j k' , {' , ,_' Staff 1 G. Odell 2 .g; Supervisor, Management Services Staf f R. C. Parker Assistant Director, Division of Quality k^%%; ,- M ,': C ' ,, - D. R. Parks Assurance Supervisor, tiaterials Analysis Mt'l J. H. Pratt Material Of ficer. Itaterials fianagement
' K. R. Ramsey Quality Assurance Engineer
,[,$,i.,r, s E. K. Sliger Supervisor, Radiological Emergency Preparedness Group 31,', j, J. R. Watson Quality Assurance Engineer cin ', fiaterials Of ficer, tiaterials tianagement 9 G. B. Workman D. Purchasing j, * . , L. N. Arms Purchasing Agent, Misclear Tuels Section D. A. Blackve11 Supervisor, tiechanical Plant Equipment y ,s *! and Special Projects Sections
.l'. 7 Supervisor, Nuclear Tuels Section
!,',; ; , C. R. Dobson -
T. W. Hannah Purchasing Agent, Open Market Electrical ,
;,1, .,
Section 3 ,. . U
~
J. E. Henegar Purchasing Agent, Components Unit i ; Quality Assurance Engineer D. E. Henry l {- ,. . . l E. C. Kidder Supervisor, Quality Assurance T. A. Lowe Assistant Director, FURCII
" W. H. tia ry Purchasing Agent, Open Market Electrical Section '
$ 'I' D. Owen Administrative Assistant, Equipment Procure-
! e,ent Branch
)[ ,.'. G. S. Owensby Administrative Assistant Materials Procure-q M' ment Branch
- p
- S. W. Palmer Purchasing Agent. Open Market Construction T ,
Section j Supervisor, Open Market Construction Section
- M- G. D. Settles D. A. Smith Purchasing Agent Nuclear Tuels Section ,
3
* ! J. M. Smith
- Purchasing Agent, Open Market Electrical Section J
f R. E. Sunderland Chief. Procurement Support Staff ,,
.s t .
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-.______l- - - _ _ - _ , . - _ .__ __ _ _ _ , _ _ __
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; ,s.U.j),'a 1. Off tee of Eastneerina .
5 Electrical Engineer y:'?.v.,c,v'l. . G. F. Orsat
' liechanical Engineer, Facility support U . .fHN20- '.d * "M '.YL. A. Johnson and Services ,
Nuclear Engineer, NIB, Design support
* ,, .k,[ A. V. Levie-T. 8. Orr Nuclear Engineer, NES, Design support.
r.
! Ant- j-- ~
J. L. Purkey Supervisor, racility Support and Services - ll
~
M ,1.I U. A. C. Robertson Supervisor, Mechaalcal Section 2
. .Ns *:;:Y I' I. B. Rosenzweig Supervisor, Cable and tiiscellaneous '
M h * !?[.'. l !.*;l s Equipewat Mechanical Engineer, Kr.B, Special Support l E. R. Taylor Electrical Engineer
- t
' 73cr , g.;J ' ',.f: W. C. Wylie
%t
I;5 .,j . .e'.. ' ' {.y,i .! T. Of fice of the General Counsel
;L ' . ~ Attorney V. W. LaRoche l ,{ -Qc u 7
.p.;f : - VII. DOCUMENTS REVIEkT.D
! fiD-1:,$'J.
- q' A. Requisitions (Esch requisition listed includes all associated documes-tation.)
9 951129 943842 h,s.t.' -'d ' . - 171173 290205 835401 925526-2 938284 938298 945707 951133 951134
,yf,[. -
940060 946728 322026 930478 951144
', h , 940163 947434 334177 931892 951819 940185 947454 341210 931941 955163
'M .t. 3 940222 950455 343910 932925 956101 940276 950509 QY i.ei.
355456 932973 942925 951019 959023 832041 . 932992 951023 959104 f([, 833678 935570 942962 959122
?.*
.;' 942988 '951028 834705 935718 ,
i b , j.'/. 834706 - 2 Il '. B. _R_etulations Standards and Upper-Tier Documents
' l
. .g I 10CTR21, Reporting of Def erts and Nonroepliance"
~ ,,
10CTR50, Domestic Licensi g of Production and Ut111:stion 9 . Tacilities"
' , }, ,
Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)" Regulatery Guide 1.29, " Seismic Design Classification" i Regulatery Guide 1.33, " Quality Assurance Program Requirements j . (Operational)"
"- Regulatory Guide 1.38, " Quality Aaaurance Requirements for Packaging,
?
Shipping, Receiving, Storage, and Handling of 1 tees f or Veter-Cooled ,. 9 l { ' meclear rower Fleets' 1.. u g as l
- I. ,.
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* }7,0: .rf 1 I.-[.p[!. f,k ((.' '
.}' -[. Y.T'? Y ]
, , g D'D. ;c~
- . j f ( ., . '
' % g l
't .*-
, ~4
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- Regulatory Guide 1.58, "Qualificatica of Nuclear Plant Inspection, >
I.'.' 7
?. Laamination, and Testing Personnel" t ',
, . ,, ;. ...c .
Regulatory Guide 1.89, " Qualification of Class II Iquipment for f 4 ..; ~ l.rp ,A Nuclear Power F1snts" - Regulatory Guide 1.123 " Quality Assurance Require enta for control t I
,1
.p.fMdlJ.'C ' of Procurement of items and Services for Nuclear Power F1sats"
,, NUR10 0302, " Remarks Presented (Questions /Answere Discussed) at
- ' t' G e.~:'...<5N.
;;; ' o _ ' Public Regional Meetings to Discuss Regulations (10CTR Part 21)
NNM f ' ',' f'lI,E!!.. for Reporting of Defects and Montoarp11ance"
. 4 : ', /. . , . r p
- FUREG-0588, " Interim Staf f Position on Environmental Qualification 4 M[ i6,7 ' - of Safety-Related Electrical Equipment"
.:x. ' *lv .
.h 1 IE Bulletin No. 79-01B. " Environmental Qualification of Class 11
' Equipment"
(.{,'
- :. . s a IE Information Notice No. 83-79, "Apparently Improper Use of )
P }[".. . , Commercial Grade Components in Safety-Related Systams" t : n, . ', yr IEEE Standard 323A-1975, "!EEE Standard for Quattfying Class 1E 2 I
... p : Equipment for Nuclear Power Generating Stations" Ci'; # *
.H ' for Class IE IEEE Standard 308-1980, "IEEE Standard Criteria .
~
Power Systems for Nuclear Power Generating Stations" y,1 :): 336-1980, "IEEE Standard Installation, Inspection, IEEE Standard ( 3 'p,';; and Testing Requirements for Class IE Instrumentation and Electric li:: Equipment at Nuclear Power Generating Stations"
;', ; , i
.- 467-1980, "IEEE Standard Quality Assurance Program -
EEE Standard 1E Instrumenta- l [.' . , ', ( f
' equirements tion for the Design and Nanutetture of Classf or, and Electric Equipment Nuclear Power i Ge 1*e . i dl
[
t 494-1975, "IEEE Standard Method for Identification
~~ ILEE Standard l l of Docuinente Related to Class IE Equipsient and Systems for Nuclear
' Power Generating Stations"
. p 627-1980, "IEEE Standard fer Design Qualification of
IEEE Standard Safety Systems Equipment Used in Nuclear Power Generating Stations" ( . . 344-1975, "IEEE Reconsiended Practices f or Seismic ! IEEE Standard
) Qualification of Class IE Equipment for Nuclear Power Generating y'A
- S ta tions"
, , l AMSI M45.2-1971, " Quality Assurance Program Require ents for Nuclear Power Plants" AMSI/ASifE M45.2.2-1978 "Pechssing Shipping, Receiving Storage, se d Esodling of' Itees ser Nuclear Power Plante" {
. i
.N 545.2.6-1978, "Qualif f s.stions of Inspection. Lamaination, h lp ARst/Asts -
1
.' and Testias Persommel f or Nuclean Power Plants" W.1 i
*
- 44
& .4 l
,s' ,
-)-
. t, J'. : -
v s [ l l - E
; i
,hc
~.'
ANSI /ASME M45.2.1 1979, "Requireeents for Collection, sto - Plants" l
..c... "
Q:hN - 'AN81 N45.2.13-1976, " Quality Assurance Requirements for Contro
..jg.,' ,}, . of Procurement of items and Services for Nuclear Power Plants .
1,a. . ANSI 18.7-1976, " Administrative Controls 'and Quality Assurance
': h *' h f or the Operatier.a1 Phase of Nuclear Power Plants"
..f:: : :,.2.l ,
a.: ANSI /ASME NQA-1-1979, " Quality Assurance Program Requirements for
' ty ;, .i' Huclear Power Plants" h %.;.' 6.'
"~
'W
.,.0 f ~
Topical Report TVA-TR75-1, Revision 8 " Quality Assurance Frosram i7 r Description for Design Construction and Operation" f
).: -
.t .1 Operation Quality Assurance nanual. Dec.-aber 31, 1983 e i 1.;L;.
;.. .g Procurement Manual, June 11, 1984
; g ,( - 21, 1983 et . 1D-QAP 4.3, "Trans f er of items ," September
.
- y.
B. Division of Nuclear Power Procedure Man.ug H72A34 " Procurement and ttateriata Support Program," March 30, l h." 1983 j V f*. N77A2, " Storage and Shelf Life Consideration for naterials with 3 ...,J..,,
.,,;.:: ' Natural Aging Life," March 21, 1983
- g .
1200R05 (H77A14), "10CTR21 Evaluation and Reporting Requirements," f i,I ' ', t October 26, 1983 l . *I. I. *. Helishility Data Syntes (MPRIML), . l 1601.02 (H73015H), " Nuclear PlantIF. Tracking and Trendina - R* Porting t *.- *.. Maintenance History and Class p l '. ..- . Failures of Components and Systems " December 9,1983
? ,[ I
{ jZ ' .",' TS 01.00.08.14.03 (N83M2), " Environmental Qualification of All { y'
- Safety-Related Electrital Equipment (IE Bulletin 79-01B and
- i
.;i .
, NUREC-0588)," July 25, 1984 ""
j.,
*- 776A4, " Standards and Substitutions Guides f or Quality Assurance
, ., 1.evel 111 Items," June 9, 1982
*(y ,
N76A10, " Purchase Specifications for CSSC Metallie Materials,
*17
- Wire, and Cable Used Inside Primary Containment,20,Velding, 1984 and 5 Brazing Materials, Valve Parts, and Pump Parts " January i
F82A17. " Equipment and Material Storage Requrlements f or Nuclear
* .. Power Stores," July 29, 1983, and September 7, 1984 .
l . i , Division of Nuclear Power Qus11ty Control Inspector Training , I . Manaal, september 30, 1982 f) y ~ g '.g,
- g. u . 49
' J . .. . . E
.- 4
- a. ,
% s" W
8 m= 1 - 4, i C, {rowneTerryNuclearPlantProcedures
. RF 16.2, " Procurement," Juas 5,1984 a, and ., -
- s. '3 '. % . -
. dim) . ~s' BP 16.3, " Quality Control of Haterisi Components, spare "- *]
/YhYy[ 8ervices," July 20, 1982 J .
I l y T*g.N[' N.&- " RT 16.4, " Material Coeponents and Spare"Parts dling, June 5,1984 Receipt, Ran Storega, lesuing, Retura to Storeroom, and Transtar,
-k,[ry.N .
d - ET 16.9, " Procurement, Ship ent and Receipt of Services an
.n.,,,,.. -
SF Material Involving Power Service shop," July 5,1983 f.:.[T M,Y; .?Y.p'i.. 29, 1982
< ,t.M ' ' BT 6.10. "TVA Pabricated Parts Used in CSSC," June
,L h.,.). /[, --
- 6. BP D11 41, " Electrical risintenance instruction 41, Raf
.t[s'<#
i!,. ,- 1979 j ; t,1.. .. . yv D. Sequoyah Nuclear Plant Procedures
,,rg
,.v, SQA45, " Quality Control of Material and Parte and Services,"
May 30, 1984 l Q. , q ' l f .*
- Al-11, " Receipt inspection, Honconf orming Items, QA level /Descrip- :
( 21, 1964 . I Q. tion Changes and Substitutions," tiay
- l l4 .f : -
Y"' E. Office of Engineering Procedure _s. l I 9 ' C-28. " Construction of Piping Systems f ar Boiling Water teactor ,
$ f Nuclear Power Plants," December 30, 1982 j i ,4.r. SS-E18.ll.04, " Quality Assurance Requirement for Electrical or
]
' g , , ,. Hechanical Equipment Requiring Seismic Category I (I.) Qualifica-
; .' 19, 1984 1 j
ji .;P tlon" June SS E18.10.01, "Environtiental Qualification Requirements for Sa'fety- : 3 .s 1984 Related Electrical Equipreent," Augumt 29, lf,*,,, !' 7 SS-E18.11.02, " Quality Assurance Requirements for Safety-Related k ', Electrical and Mechanical (Non-ASME Section III) Equipment," ; f ,',' gi i June 19, 1984 ; r SS-E18.ll.01, " Quality Assurance Requires,ents for ASME Code, j 3
- - Section 111 Control Valves," Hay 26, 1983 SS-E18.ll.03, " Quality Assurance Requirements (Certificate of Conformance)," June 19, 1984 k IDP-N 51.05, " Preparation and Processing of Preliminary Design ,
[ Change Requesta (P DCR) " May 9, 1983 IDP*N 51.03, " Modification leptementation and Control Modificattoa I ! 4- Tracking Progree," January ll,1984 a { ' 50 o l af stq M ,
- ,-~----
l ., f') q L v ( IDF-N S4.01, "NUC PR Frecurement Request to D DES," May 9,1983
, IDP-N 50.02, " Division of Noelear Power and Insineertog Design -
j 4 .7. ' . -.i . ., laterfaces," March 1, 1984 ,
%'.ph'.p';. f.' 30, 1984
ID-QAF 2.4, "CoAtrol of Hodifications," March Program Require- .
e
M18-EP 23.5.5, " Specification77, of1983 t/uality ' Assurance
;1,[I ' ' '
ments for HER Requisitions " May "v. .sf *
'
- T T. Correspondence and Reports d Augsat 13, .
I Report to
, Neocrandum f rom T. W. Cheadler to J. A. Raulston dat '
24, 1984, on TVA s Enviroa-
"l/6 % *'? ' -
h nta L '! * ' t ' NRC Resulting from NRC Meeting of Maymental Qualification Progra
...[ff (EIB 840813 938) 6, 1984, f ree Vyle Laboratories dated January Opera-Test Report 17503-1
($ " Control Equipment Consisting of Therminal i Blocks, Pushbutton Cables" 4 A '- , tors, Selector Switches and contact Blocks and Var ous l 10,
; ,,,5- letter f rom Ric hard T. Troselair to N, M. Sprouse dated Apri
* % 1972 " Contract 71C-3-54360, 70C-61-54041 and 69C5-64%5"
, ,, 19, 1971, inland Testing Labora-Iest Report 3359B dated November Compoonata for
- tories, Inc., " Report of Test on (20) Switching I =: [~. Cutler Hammer" 10,
- *? *#
I c.i.'- Hemorandum f rom E ic Kvsven to James P. Darling dated Augustfor S i [* 1984, " Report of the Task Force )"
' 4 ment Problems in the Of fice of Nuclear Power (NUC PR
- jl *
(LOO 840810 294) n ip. y 5 .t , Letter from R. H. F.ctor to George J. O' Dell dated April 6, 1984, "Brief Procurement Process Analysis of Tield31, Services Branch 1982" {g ' '- . Purchase Requisitions Originated June 1 to Deccaber j :V - (L12 840405 813) li-f dated Tebruary 25, 1983, " Environmental Qua s. dit il Report CH-8200-14fication Program," by Office of Power Quality Assu Staff (0QA 830225 703) h R. L. Lwephin, Jr. , dated May 10,(0QA 830511 700 Hemorandum from H. J. Creen to1983, " Quality Plant Program Audit Repo l t dated March I,1984, "8rosne Ferry Nuc ear k. 2
- Report BF 8400-03, Procurement /St.orage Activities" (0QA 840220 101)
- br6, d
a *
. s*
Memorendum f rom H. N. Sprouse 17, 1981" to H. J. Green , Services, N-OQAM Part III, Section 2.1, dated April (II.B 811110 912) 4 ., . . ' t .. a 51
,t.j Scd . .
- - - - _ _ _ _ _ . , _ _ wm. - . __
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.i Files * ,9 lbmerande from G. A. Neller to Electrical En8toseria8 Development of a -
c ; (' ,'. T < dated Amaust 23, 1983, "All Nuclear Plante aPr68 aa (CEQP)"
-* Comprobessive Envirsumental Qualification f
,WA. . * &o, ca f 'nf f., . . d September 14, ,
lg [ .Itsoorende f ree T. O. Campbell to Those listed date '
+ '! . ,
I 8.h'"9tM[!Sf'J.N' Eh :q1983, "Procurseest of C1sse II Euipment - All Iluclear Plants - a
.}[Sifl .", Field Bervices" . (L23 830813 884) .98I ,
,, . , . - {. . . 19, 1983, .; (
+ ..;;z ;;j.
3 jf_s ,;' Memorandum from T. E. Spink to 0QAB files dated October "Neting of 8pecial Evaluation Team - Environmental Qualification 'i
- f, g,': ' ~
.h .
of Safety-Related Equipment with Duke Power" 4 ,3.* 19, 1983, . j .- Memorandum from T. E. Spink to OQAB Til.,a dated October f
" Meeting of Special Evolustion Team - Environmental Qualification (CECO)"
of Saf ety-Relat ed Equipment with Coe onwealth Edison Company ... l e g { 4 ! Memorandum f rom II. J. Green to James P. Darlios, et al, dated l July 25,1983, " Browns Ferry and Sequoyah Nuclear Safety Reviev > [ j - Boards' Annual Report for 1982" 4 l Memorandum f rom R. L. Lumpkin, Jr. , to F. A. Szczesponski dated ( August 16,1983, " Browns Ferry and Sequoyab Nuclear Safety Review Boards' Annual Report for 1982" (OQA 830816 700) Heriorandum f rom 11. J. Green to James P. Darling, et al, September 22, 1983, " Browns Terry and Sequoyah Nucteer Saf ety Review Boards' (HSRB) Annual Report for 1982" (L69 830916 800) Hesiorandum from P. R. Wallate to Those listed dated February 15,
- 8. * ,
1984, " Browns t erry. Sequoyah, and Watta Bar Huelcar Plante -
'.! heintenance' Act tvity of Class IE Equipme-nt" (DES R40209 002) ~ '
# Hemo,randum f rom liarold R. Denton, NEC, to Villiam J. Dirchs, NRC, l, dated January 21, 1983, " Equipment Qualification Program Plan" p .
Form TVA 45 f rom George J. Odell to Dick Srsith dated December 10, , ( 1984,1 " Materials Management Section Training Sessions" I Memorandum f rom James L. Villiams, Jr., to Those listed dated June 4,1984, "Premoting a Better 11nderstanding of TVA's Purchasing J
. M. Tunction"
- g. Memorandum f rom flerbert S. Senger, Jr., to V. T. Villis dated -
"i* . .
October 20,19H3, "Public Law No. 98 Handatory 45-Day Waiting l Period - Procurement and Personal Services Contracts" 5f ? I hemoreadam from V. P. Villis to Those listed dated October 31, 5 1983, "Public I.ev No. ai Mandatory 45 Day Velting Period E 9 ACT - Arylicaties to Precurement and Personal Services Centracts" f Mmmereedus f rous James L. V1111ame, Jr., to Beads of Of fices and L) Pivistees dated lievember 3,1983, "P1mblic Lew Be. 98 Emede- d
- tery 45-Owy Westleg Period - Procurseest Centracts"
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' Revember 8,1983, "hblic Law No.'98 Mandatory 45 Der Wittas hried Act . Estent of TVA'. Yetsstery Compliance for s
f j.
, ,. Peiser Progree Centracts" *
.;. . .h : . ' ' ,y , . ,
.c. > ,
, t g . . . , , c . ; ., ( ,,. . -, -Bemerende f ree R.-H. Crime, Jr., to Those listed dated December 12, ,
f "5 1M3, 'Public Lev pe. 98 72 - Mandatory 45-Day Waiting Ferled . . . 8' D. *-
;%)Q.l':.',,'
,'v'. ih' . .. .. . Act - Entest et TVA's Voluntary Compliance for Fower Frogras
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I Meeorandums f rom W. T. Willis to Those listed dated February 3, '
,'l :- .d.7 '
1984, "Public Law 98 Mandatory 45-Oey Waiting Period - [ . Applicatica to Procurement and Personal Services Contracts"
'. t. . l.,
.. ,b '"
. it Memorandum f ree J. A. Cof fey to Those lleted dated February 29, i , ~- 4; 1984, "Public Law 98 Mandatory 45-Day Wetting Period -
' 'p ,* .' : ,
Application to Division of Nuclear Power Procuremente" ..
, ,' : ' , ' (L25 840301 460) 6>, ,.
' .q y ,i . .> Memorandum f rom J. G. Holmes , Jr. , to H. S. Sanger, Jr. , dated March 15,1984. "Publie Law No. 98 Mandatory 45 Day Waiting '
' l ?. ' ' . ..< Period Act - Extent of TVA'n Voluntary Compliance for Power
! J ,'.l.' " Progree Contracts" (LOO 840319 474)
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m probless starting .,df
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. WERS elftre en approath 'te solving NUC PR procurement y j
! f .'r),/* the beste preeseement fumettee. As attitude change should occur of items is censidered for what it is--a very
'h.7 %d.Qp;,/.with '
-'i .,
tapettant fenettee. Precurement within TVA in anylaposition not simple and at requires a , h Tf/j ,0'.:.M ef;.,4bertby the preestement currently
..* k:.;f% ; i'.,,P. :.'qr y/Uf l' level of The espertise knowledgeand knowledge and experience mustnot inherent be taught and leerm d. ,'( *=
j .k., , 4,i,NW the pl ante. the time delays and inadequaclei are associated to a larse ydy';4. * { M..W g.c ,,..Fresently, learning on their owes how to procure things. N8R8 a
,.jj G,$ ** . :, eenteeds esteet with thatIndividuele procurement of items should be elevated in stature and - -
~; t F * '
imipertence to a professional level. v:9 . 3
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To make the toncept work, NUC FR should change its practice that everyoneto one where a dedic
_ 11;,, esa and abould be able to procure materials People need to know how
?,/ ,
treined staff provides all procurement services. With proper train- g <- i ., to procure things before they are f aaced ing, a materialswithstandpoint the task.significant as number o
. . r.
quality of the procurement process, both from A training program on {.
':v': well as a time delay standpoint, could be improved. V' the entire procurement process to include TVA's procedures, quality f*h J
hql requirements, purchasing requirements, and Federal procurement requirementsperf orm r . developed and provided to Personnel abould be Satisfactory y . !. feettion. completion of that training should be a requirement (,y
,W, before an individual is allowed to procure anything. i
'f ; ;p 4 y ..
Am entension to the training requirement couldofbe the establishment materials, of a la that con- [. r'.;I. .] , group whose responsibility is the procurement g j
) f':
yg' *7', cept, entineers requiring items or services would That group staf fedgo with to the theprocurement necessary
- g group and specify what was needed.
j expertise would , "in turn, prepare the necessary procurement documents. a ;
's^,
define the material spe ications, quality requirements, and provide f ficial, be it the p . U fi. '
- i
, completed pro'curement pawge ready for the approv ng oThat staff would be responsible
{,Q,),,, , 1
- F1 sat fianager' or the Board of Directors. were correct and require no further for assaring that the
. /.
- review or approval withprocurementsexception the of the authorizing official (s) and Power Stores personnel and their ordering
} .a interf ace directly with FtTRCH. included in this staf f but would work closely
[
. , ::J. of stoch items would not be with them ou procurements of stocked quality level materials.
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t$ ATTACHMENT D CONCERN IN-86-011-003/0E-QMS-1 BACK-UP-DATA 2/24/83 NRC IE Info Notice 83-06
- A02830302008 2/25/83 QA Audit Report CH-8200-14 OQA830225703 6/29/84 HRC IE Info Notice 84-52 A02840705005 NSRS Report R-84-17-NPS Q01850312051 3/12/85 3/12/85 K. W. Whitt to J. P. Darling Q01350312050 4/18/85 S. Johnson to Watts Bar Nuclear files B45850521603 5/08/85 NRC IE Info Notice 84-52-S-1 A02850513006 J. P. Darling to K. W. Whitt L12850520800 5/21/85 8/12/85 J. Cilbert to K. Brown Pandwritten Memo N. R. Beasley to C. R. Hall B22850925002 9/25/85 10/25/85 A. M. Qualls to J. C. Standifer U00851025804 J. P. Vineyard to N. R. Beasley B25851029003 10/29/85 J. C. Standifer to N. R. Beasley B21851031002 10/31/85 11/05/85 J. D. Carlson to C. R. Hall R32851105869 W. B. Hopf to Brown Ferry Eng.
B22851106023 11/06/85 11/07/85 R. L. Lewis to G. R. Hall R45851031878 11/22/85 P. R. Wallace to H. B. Rankin LO485118933 J. P. Vineyard to N. R. Beasley B25851129015 11/29/85 12/20/85 J. E. Law to C. R. Hall L16851220825 1/21/86 F. R. Hall to N. R. Beasley R25860122878 5/06/86 F. E. Dicola to W. C. Drotleff B01860506002 L15860429801.., 5/21/86 S. A. White to "Those Listed" R. O. Barnett to C. A. Chandley B41860606014 6/06/86 W. S. Raughley i 6/23/86 W. C. Brotleff to "Those Listed" B44860619171 7/09/86 J. H. Millet of J. P. Stapleton o L298160701846 7/22/86 S. A. White to "Those Listed" L67860722863 7/24/86 F. E. Dicola to "Those Listed" B45860725000 (Draft NQAM Procedure) 8/06/86 W. L. Elliott to Z..Kabiri B70860806005 D. Reia 8/08/86 J. P. Stapleton to "Those Listed" B22860808015 n
'~h , .. ~ . v ATTACHMENT E 4 .
CONCERN KK-85-116-008 BACK-UP-DATA
- 1. Appendix "B" to 10CFR50, Criterion XVIII, Audits.
. 2. NQAM, Part III, Section 5.1, Audits.
- 3. DQAI - 310; DQAI - 313, Rev. O and Rev.1, DQAI - 104, Rev. O and Rev.1
- 4. Q. A. Reader Files, January through December 1985
- 5. Q. A. Reader Files, July, August and September 1983 l 6. Sequoyah Audit Reports:
SQ-8400-10 SQ-A-85-0003 j SQ-8400-14 SQ-A-85-0008 SQ-8400-06 SQ-8400-09 SQ-8400-13
- 7. Mulit-site Audit Reports t l
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 WB-8400-04 QWB-A-85-0013 WB-8400-03 ^
- 9. Browns Ferry Audit Reports:
BF-8400-04 BF-8500-03 i BF-8400-14 QBF-A-85-0006 BF-8400-08
- 10. Memo to Site Directors from H. G. Parris, dated 6/13/84.
- 11. Memo to W. C. Bibb from G. W. Killian, dated 12/7/85.
! 12. Memo to R. J. Mullin from G. W. Killian, dated 5/30/85. 11/14/85.
- 13. Memo to Quality Audit Branch from G. W. Killian, dated 14.
Memo to H. L. Abercrombie from G. W. Killian, dated 9/23/85.
- 15. Memo to G. W. Killian from H. L. Abercrombie, dated 7/31/85. I
- 16. Memo to H. L. Abercrombie from G. W. Killian, datedC. 9/23/85.
H. Whittemore, and I A. Audit File from C. E. Bosley, J 17. Memo to Q. W. E. Aslinger, dated 6/10/85. Memo to Quality Audit Branch from G. W. Killian, dated 11/14/85. i 18.
- 19. Quaterly DQA, Quality Problem Status Meeting Hinutes, dated 6/17/85.
- 20. Memo to "Tho'se. Listed" from G. W. Killian, dated 4/19/85. G. W. Killian, dated
- 21. Interoffice Mailing Slip, 45D, to all QAB from l' 5/10/85.
i 4 L 1
/-
( .I I . '. .T g* e i . ATTACHMENT F
/
.V '
ECSP CORRECTIVE Action Tracking Document (CATD) INITIATION
- 1. Inunediate Corrective Action Required: d/ Yes /[/ No
- 2. Stop Work Recomunended: // Yes /I/ No I
- 3. CATD No. 80101-SQN -01 4. ~ INITIATION DATE 9/8/36
- 5. Office of Nuclear Power
- 6. RESPONSIBLE PROBLEM DESCRIPTION:ORGANIZATION:__
/I/ 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) the Action is being taken for the present procurements, however, indicate what documentation reviewed and discussions held did not 4
action is being taken on previous procured items. Attachment - Element Report 80101-SQH 1
/ /ATTAClutENTS DATE: 9 /f/f*/
- 7. PREPARED BY: NAME W. E. Bezanson DATE: G /4 / f'(/
- 8. CONCURRENCE: CEG-ll g g//M = f ' '
/' DATE:
- 9. APPROVAL: ECTG PROGRM1 MGR:
CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
/X/ATTACl&lENTS DATE:
- 11. PROPOSED BY DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG-il DATE:
SRP: DATE: ECTG PROGRAM MGR: _ i VERIFICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified as satisfactorily implemented.
TITLE DATE SIGNATURE 6
~-
__g - --- _ , _ . _ . _ . .
~
ATTACHMENT G
*E 1 cf 35
$ 0102 M1 E ES GOVERNMENT TENNESSEE VALLEY AUTHORITY
' Memorandum
- W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, To Watts Bar Nuclear Plant FROM : H. L. Abercrombie, Site Director, ONP, OLPS-4, Seguoyah Nuclear Plant DATE : January 6, 1987
SUBJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS REPORT 801.01 SQN - QUALITY ASSURANCE CATEGORY - CORRE PLAN (CAP) Your memorandum to me dated September 9, 1986, " Watts Bar
Reference:
Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80101-SQN - Quality Assurance Program Adeguacy (Seguoyah)" (T25 860909 967) I acknowledge receipt of your element report and in accordance with your reguest (see reference), Element Report 801.01 SQN has been reviewed for applicable corrective action. By way of this memorandum I am endorsing the site line organization CAP, returning your Corrective Action Tracking Document This No. CAP80101-SQN, is,a restart and attaching the CAP for your review / concurrence. requirement. If you agree with the proposed CAP, please sign the ECTG concurrence space below item 9 on the CAP tracking checklist and return the CAP tracking checklist. ,
$$h H. L. Abercrombie l
l RECElvED RCD:JDS:JB:CS Attachments ,iLij M.7 cc (Attachments): RIMS, MR AN 72A-C (B25 '861231 011) T5%fgg,gitsk
- 7. C. Price, 5-212 SB-K it.cneImp. : w.,
.p ;
0507I 7tB t M. (
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ATTACHMENT G- E 2 of 35
^'
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Q
- ECSP CORRECTIVE Action Tracking Document
.' . (CATD) 1 INITIATION
- 1. Immediate Corrective Action Required: /Y/ Yes / / No
- 2. Stop Work Recomunended: /;/ Yes /X/ No
- 3. CATD No. 80101-SQN __4 . INITIATION DATE 9/8/36
- 5. RESPONSIBLE ORGANIZATION: Office of Nuclear Power
- 6. PROBLEH DESCRIPTION: /X/ QR /[/ NQR Procurement program did not assure. safety related materials, com-ponents, devices equipment, systems etc., procured by the Power Stores /Huclear Plant Power Operations Process complied with .
applicable regulatory, design bases and qualification reouire-inents . (Concern OE-QMS-1) the Action is being taken for the present procurements, however, indicate what documentation reviewed and discussions held did not action is being taken on previous procured items. Attachment - Element Report 80101-SQN i
/ /ATTACID1ENTS W. E. Be:anson DATE: 9 /9/f'M
- 7. PREPARED BY: NAME
- ,YY/ /M -- / DATE: G /4 /f'(/ *
- 8. CONCURRENCE: -CEG-H / DATE:
4
- 9. APPROVAL: ECTG PROGRAM MGR:
CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
T6F T#d'~ h[ FMA/'/f[D ' RY AffAfoKANbuA/l B76 7 6 /2 %! O// i
/X / ATTACl!!!EHTS PROPOSED BY: DIRECTOR /MGR: g 47 sR, i l //m PA t: /-E-/O
- 11. '
DATE:
- 12. CONCURRENCE: CEG-H DATE:
l . SRP
- DATE
ECTG PROGRAM MGR: i l VERIFICATION AND CLOSE0UT Approved corrective actions have been verified as satisfactorily 13. 1 implemented. . TITLE DATE SIGNATURE e 1
- I 1
I
- ATTACHMENT G I.
's -
.E 3 cf 35 y vs .,,
si v N - aUNITED STATES COVERNME.~T
'Memoyartdum QA.Reierd TENNESSEE VAREY AUTHO B25 '86 r2 3 0 011
~
R.Sequoyah C. Denney, Etaployee Concerns Special Project Manager To : .,_
. Nuclear Plant TROM : D. W. Wilson, Project Engineer, Sequoyah Engineering Project, Sequoyah Nuclear Plant DATE :
DEC 3119B6
SUBJECT:
SIQUDYAH NUCLEAR PLANT (SQU) - EMPLOYEE CO.NCE REPORTS - REPORT S01.01 SQN - REVIEW AND CORREC INITIATION ' Please reierence the memorandum to Z. M. Kabiri f. rem you dated Septemb
- 22, 1986 (503 86091 8 802).'. . .:
attached is the subject CAP and copy of the existing or Per your request, ,; intiating corrective action documentation. - [ ~ fh
'D. W. Wit' son ,.
. t" ,
g *- g,,TES :LJJ ,?' Attachments . ..: ec ' (Atta chment s ):
~
,N ...
i - - RIES, SL 26,C-X .~ E. L. Abercreebie, 'ONP, O&PS-4, .Sequoyah (v/o, Attachment s)
- I
- W. E. Andrevs, DNQL, O&PS-3, Sequoyah - .
C. E Euchanan, CNP, O&PS-3, Sequoyah (w/o Attach =ents) * , E. W. Olsen, DHC,' SE-2, Sequoyah ~
' T. C. Price, W10 A57 C-K
( P.. D*. Rudder , DNE, DS C-I, Sequoyah E' J. Scruggs, V8 2121 C-K ,. I J. ,R Sullivan, ONP, SB-2, Sequoyah ** Principally Prepared by T. I. Spink, Extensics 7162',,Ti
~
- a. .-
. 2
.c (a
s s- , S, S:IF te :. 30. 1.c is , _ , l
IE 4 cf 35 as
- (v ATTACHMENT G i
* . Standard Practice Page 8 l 1
- SQA166 Revis' ion 8 Attachment A Page 1 of 2 -
Corrective Action Plan of Employee Concern Investigation Tracking Checklist
..gay,. t ),
.fi y.g. ; ECTG Report /CATD Number 801.01 SON /80101 - SON Lead Organization Responsible for Corrective Action Plan DNE
, Initiation Date November 24. 1986 CORRECTIVE ACTION PLAN (CAP)
- 1. Does this report require corrective action? Yes X No (If yes, describe corrective action to be;taken, if no, provide justification) i See Attachment I
} i i 2. Identify any similar item / instances and corrective action taken. i CAO recentiv issued at Bellefonte. Corrective Action unknown l I
- 3. Will corrective action preclude recurrence of findings? Yes _ y No
- 4. Does this report contain findings that are conditions adverse to cuality (CAQ)
YES y No l, as defined by AI-12 or NEP 9.17 5.-IT a CAQ condition exists, what CAQ document was initiated? NRC Renort (50-327. 328/86-61) dated N'ovember 14. 1986 (A02 R61110 noti
- 6. Which site section/organi=ation is responsible for corrective action?
DNE - Renlacement Iteme Pronram
- 7. Is corrective action required for restart? Yes _ y No j
(This determination is to be made using Attachment C of SQA166.) - l 1314
- 8. P2 zone numher for restart corrective action? Zone i
- 9. Estimate completion date for correction action. ifas .
~
Completed By Ir Date /r./sc/94 Approved By (41////A//fM Date /7Artths
# ~ , ECTG Concurrence Date I,
) , i i l . l l 0206S/elt l I l l
. . . . . - - . . . . _ . _ . ._ . . _ _ . -. - _ _ _ _ - . _ ~
s
.is
-s ATTACHMENT C
' v E 5 cf 35
. Standard Practice Page 9
. SQA166
~*
Revision 8 (A ATTAC10G2fT A i Page 2 of 2 t '. CAP CLCSURE s - i 10. Was your corrective action initiated and completed in accordance with step 17 Yes No
- 11. If step 10 is no, describe the corrective action taken.. ,
t l- . e. l .
- 12. Is the corrective action implementation complete? .
Yes- No e 13. Is the co,rrective action documentation closed? Yes No onts were used to implement the corrective' action? 4 14.WhatdocyBy: Complefad Data Verified By: Date ' 4 Date .i ECTGl : - Closure: . s (Step No.) Description . 1 i
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y ATTACHMENT G b j 7 0F 35 Attachment REPLACEMENT ITEMS PROGRAM The purpose of the Replacement Items Program is to develop and implement a
- commercial grade dedication program and evaluate selected replacement part installations to determine their adequacy for use in safety related applications. The attached Figure 1 is a flow diagram of the program. A more detailed description follows.
A new procedure to establish a TVA process for the dedication of commercial grade items for use as basic components has been issued in the NQAM, Part I, Section 2.7.2. Both DNE and Site procedures are being developed to implement the NQAM requirements. A DNE technical procedure is being prepared to establish the process for the engineering evaluation to develop the requirements for Ultimately, dedicating a commercial-grade item as a safety related item. this procedure will be issued as an NEP, establishing a generic technical process for dedication,throughout ONP. SQN Site procedures in the area of procurement, storage, receipt inspection, maintenance, and reporting are being revised to reflect dedication requirements. Project procedures are being developed to control installation document identification and review l tasts as well as other pertinent activities. W' 4 W e
;g P'ii;E 8 of 35
. ATTACIDKNT G A conditional inventory issue program will ensure that current replacement parts are dedicated. A tracking program was implemented on November 25, 1986 to identify replacement part usage. When dedication procedures are developed, inventory issuances will be screened by engineers with dedication documentation prepared within 30 days. Additionally, all new receipts will have dedication initiated at receipt inspection.
The Procurement program is being revised to initlate dedication at the requisition stage for new safety-related procurements. Prior to restart, replacement parts for 10 CFR 50.49 (Environmentally Qualified) equipment will be identified and dispositioned with the preparation of dedicated documentation as appropriate. As a longer term effort, the existing Power Stores inventory will be evaluated and appropriate dedication documentation prepared. Any item with a potential safety-related application which cannot be dedicated will be , i . reviewed for past.. unacceptable usage and corrective action will be initiated if required. 1 Ultimately a mini-specification program will result in a controlled engineering output in the form of pre-engineered specifications detailing i part technical requirements, source audit and inspection requirements, receipt inspection requirements, part conditioning requirements, and if l d applicable, part maintenance testing requirements. 0064W i I
ATTACHMENT G . E 9 cf 35 h
.? ^ .l . \- 102 8 6111 EO O 5 Dm.S
.- . . .[. p,mer'o, UNITED STATES EC* CC/r) y i NUCLEAR REGULATORY COMMISSION
- WASHINGTON, D. C. 20555 . g .7 9 . .pw Hovember 14, 1936
, ... ,e
- Docket Nos.
- 50-327
- n. and 50-328 ,
7.!p. > op : l 2- Tennessee . Valley Authority , i ATTN: Mr.-C. C. Mason Acting Manager of Nuclear Power ei.g 6N 38A Lookout Place . - 1 1101 Market Place - 6 Chattanooga, Tennessee 37402-2801 i [ :,
'. Gentlemen:
This refers to the inspection performed by Messrs. E. T. Baker, J, C. Harper, and
; J. J. Petrosino of the Vendor Program Branch and Mr. S. R. Stein of the Reactor Construction Programs Branch on September 15-19 and September 26 thru October 3, 1986, at the Sequoyah Nuclear. Plant, Units 1 and 2. The inspection related to activities authorized by NRC License Nos. DPR-77 and DPR-79. Our findings were
< discussed with Mr. H. L. Abercrombie and others of your staff at the conclusion of the inspection and were the subject of the October 21, 1986 letter from
! r l { J. M. Taylor to S. A. White.
' q . The purpose of this inspection was to review Tennessee Valley Authority's (TVA) ~ I corrective action to Nuclear Safety Review Staff (NSRS) Reports R-84-17-NPS, ! I-83-13-NPS, and R-85-07-NPS. The inspection included a review of contracts - for original and replacement equipment, maintenance requests, quality assurance program requirements, site procurement procedures and practices, and associated documentation. The findings in the areas of procurement of safety-related equip-i ment, record storage and retrieval, and receipt inspection indicate a failure to .
. take adeounte corrective action to these previously identified concerns. In l
s particular, your program has allowed previously qualified equipment (seismic and l " l: ,.. . environmental) to be degraded by purchasing replacement components and parts as commercial grade, without documentation of its qualification, and without adequate - !.. dedication of the items by TVA. In addition, retrieval of quality assurance l d,, . records for installed equipment was extremely difficult and in some instances,
** where the equipment did not have a unique plant identification number, the records could n'ot be retrieved. Further, in some cases receipt inspectors have not been provided with adequate instructions to enable them to perform j meaningful inspections. These deficiencies have been classified as a single -
4 Potential Enforcement Finding (50-327, 328/86-61-01) concerning failure to
, take adequate corrective action. .
I cuciavan - }i . }CHAirNJoOGA.rLot e NOV 191983 i $ swo.os... e ) { . , t OFMcIE*C~JutPctr-d. -
. _ a .__-..
I
D ATTACHMENT G bd10of35
?.*
Tennessee Valley Authority November 14, 1936 The Potential Enforcement Finding is being teferred to the NRC Region II office . for their review and appropriate action. Your corrective action for Sequoyah and assessment of the applicability of the identified deficiencies for other TVA facilities should not await further NRC action.
~
Should you have any questions on this matter, we would be pleased to discuss them with you. Sincerely, s pg _1 t Brian K. Grimes, Director Division of. Quality Assurance, Vendor
.. and Technical Training Center Programs ,
Office of Inspection and Enforcement
Enclosure:
- 1. Potential Enforcement Finding 50-327, 328/86-61-01
- 2. Inspection Report No. 50-327,328/86-61 cc w/ enclosures:
H. L. Abercrombie, Sequoyah Nuclear Plant Site Director Post Office Box 2000 - Soddy-Daisy, Tennessee 37379 P. R. Wallace, Plant Manag'er Post Office Box 2000 - Soddy-Daisy, Ten,nessee 37339 J. A. Kirkebo, Director , Nuclear Engineering . Tennessee Valley Authority
- 400 West Summit Hill Drive, W12 A12 -
Knoxville, Tennessee 37902 - R. L. Gridley, Director Nucicar Safety and Licensing *
- Tennessee Valley Authority 5N157B Lookout Place
." Chattanooga, Tenness,ee 37402-2P.01 ,
M. R. Harding, Site Licensing i Manager Tennessee-Valley Authority SN 157B Lookout Place y Chattanooga, Tennessee 37402-2801 l I
> . . g v
' 8 lETIACHMENT G PACE 11 of 35
,r POTENTIAL.EHFORCEMENT FINDING l((~
Tennessee Valley Authority Docket Nos.: 50-327/328 1101 Market Place License Hos.: DPR-77/79 Chattanooga, Tennessee 37402-2801 Potential Enforcement Findino 50-327, 328/86-61-01 i t As a result of the inspection conducted on September 15-19. and September 29-October 3,1986, and in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the following Potential Enforcement finding was identified. 10 CFR Appendix B, Criterion XVI, states, in part, " Measures chall be estab-lished to assure that conditions adverse to quality, such i's failures, malfunc-tions, deficiencies, deviations, defective material and equipment, and noncon-
~
formances are promptly identified and corrected." I Contrary to the above, TVA has failed "to correct deficiencies in the areas of procurement of safety-related equipment, storage and- retrieval of quality assur-ance records, and receipt inspection of safety-related equipment which were identified in Nuclear Safety Review Staff Reports R-84-17-NPS, I-83-13-NPS, and d R-85-07-NPS. 1 i 4e I . e l* - e e g. O h j - k m
g ATTACHMENT C hAGE 12 of 35 Report No.: 50-327/86-61 and 50-328/E6-61 . (f Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street . Chattanooga, TN 37402-2801 Docket Hos. 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah Nuclear Station Units 1 and 2 Inspection Ccnducted: September 15-19 and September 29-October 3, 1986 Inspectors: CT} E. Baker, lea cU cer UhkN Data it. Lad .k ,.' // C
/J. 6 Petrosino, Quality Assurance Specialist Dase
/ff/i!fd
'S. R. Stein, Electrical Engineer Date
. .x . -
N V h., J. C. Harper, Metallurg1 cal Engineer Date i Approved by: . n r!n E. W. Mersenoff, , Reactive Inspection Date .
- Section, Vendor ogram Branch i
SUMMARY
Scope: This was an announced reactive inspection which was conducted at the Sequoyah Nuclehr Station to detern'ne the effectiveness of TVA's corrective
- i. action for problems identified in Nuclear Safety Review Staff Reports -
R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS concerning past procurement and record storage practices. Areas inspected included procurement actions taken
. 'for replacement of safety-related electrical and mechanical components of the residual heat remova'1, control air, and emergency power (diesel oenerator) systems; a siample of procurement actions identified by TVA's review of Class IE replacement devices; a sample of procurement actions taken on equipment l
selected during a plant walk-through; NDE personnel qualifications; and Power Stores receiving inspection practices. Results: One Potential Enforcement Finding was identified.
*
- ATTACHMENT G P' AGE 13 of 35
- REPORT DETAILS lC
( *
- 1. Persons Contacted:
Licensee Emolovees
*H. L. Abercrombie, Site Director
*W. E. Andrews, Site Quality Manager
+J. Blankenship, Information Office Manager L. D. Brewer, Control Shif t Operator R. Bruce, Program and Standards Section Supervisor
*R. H. Buchholz, Office of Nuclear Projects (ONP) Site Representative
*S. K. Chapman, Electrical Maintenance General Foreman M. Crane, Site Services Procurement Supervisor
*D. C. Craven, Quality Assurance Manager
*M. R. Harding, Site Licensing Manager R. Jenkins, Divisien of Nuclear Engineering (Dt!E) Supervisor
*2. M. Kabiri, Site Services Manager
*J. W. Kelly, EA Engineer G. Kirk, TVA Compliance T. Kontovich, Electrical Maintenance Engineering Supervisor
*J. E. Law, Chief Quality Systems Branch
*A. S Lehr, Instrument Maintenance Group Engineer
*H. R. Matthews, Restart Task Force
*B. Patterson, Maintenance Superintendent G. W. Petty, Materials Officer H. L. Pope, QC Supervisor
*H. A. Purcell, Licensing Engineer
*B. Schofield, Licensing Engineer
*J. R. Staley, Power Stores Supervisor C. Stut2, CA Engineer
*P. R. Wallace, Plant Manager
*J. R. Watson, OA Engineer
*W. J. Wilburn, Site Maintenance .
*L. J;. Wheeler, Materials Manager
*C. R. Wherter, Materials and Procurement Services Staff Chief The; inspectors a" Iso contacted or interviewed other licensee personnel
. from the operations, training, maintennte, and technical staff.
Other Orcanizations R. V. Matheison, Westinghouse Site Representative .
.- flRC
*P. E, Harmon, Resident Inspector
*K. M. Jenison, Senior Resident Inspector
.* *D. P. Loveless, Resident Inspector
.*E. W. Herschoff, Chief, Reactive Inspection Section
- attended exit meeting 2
I __.
e
~*
- U ATTACHMENT G MGE 14 of 35
- 2. Exit interview --
f The inspection sccpe and findings were summarized and ciscussed with those individuals identified in paragraph 1, above. The team members described the areas inspected and discussed the inspection findings - listed below. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
- 3. Licensee Action on Previous Enforcement Matters This subject was n6t addressed in this inspection.
- 4. Unresolved Issues ,
No unresolved issues were identified during the inspection.
- 5. Backoround TVA's Nuclear Safety Review Staff (HSRS) performed in-depth audits of TVA's procurement system and records retention system. The results of these audits are documented in reports I-83-13-NPS dated June 17, 1983, R-84.17-NPS dated P. arch 8, 1985 and R-85-07-NPS dated July 5, 1985. These reports high-lighted programmatic deficiencies without providing specific examplet of the problems found. One of the more significant findings related to the use of components purchased " commercial grade" and used in safety-related systems without any additional determination by TVA of the components' qualifications for use in safety-related applications. Another significant finding dealt with the difficulty or inability to retrieve quality assurance records in a tinely manner. TVA took corrective action in response to these findings i
- to improve their procurement and record storage programs to prevent similar problems from recurring. However, these corrective actions did not appear to address the effect past procurement practices may have had on the cuality of installed ecuipment. -
l - This. inspection was conducted to determine how procurement practices for original and replacement components and parts affected the original quali-l fication or design requirements of safety-related equipment installed in the plant or if record storage practices prevent determining whether or not the qualification of equipment has been adversely affected. The inspection l, - utilized three separate methods for selecting equipment for detailed l review: l a. A sainple of electrical, mechanical, and instrumentation ecmponents l was selected during a, plant walk-through for a review of the related ~ procurement documents. Equipment was selected bEsed on problems identified during previous inspections of licensees and vendors. l .* Preblems noted in paragraph 6.b.7 were identified for an item from this sample. i s e f ( 3 i i
"..' . L ATTACHMENT G UE15ef35
- b. A computer listing of maintenance requests (11Rs) initiated during the time pericd 1980 to 1904 was obtair.ed for selected systems and q/ MRs were selected from these lists for follow-up based on whether
( or not a safety-related component was replaced. Problems noted in paragraphs 6.b.1, 6.b.6, 6.b.9, 7.a. and 7.b were identified for items drawn from this sample.
- c. TVA began an effort in July 1986 to evaluate the seismic qualifica-tions for a sample of Class 1E cevices that had been replaced. From a total of approximately 125,000 MRs, they identified 238 MRs under which Class IE devices had been replaced. At the time of this inspec-tion TVA was in the process of determining the status of seismic qualification for a sample of 50 MRs' which represented Class IE replacement devices . supplied directly from stock. This inspection reviewed several MRs from the 238 that were not part of TVA's sample of 50. Problems noted in paragraphs 6.b.2, 6.b.3, 6.b.4, and 6.b.5 were identified for items drawn frcm this sample.
- 6. Review of Procurement
- a. Procram Review The team reviewed Part III, Section 2.1, " Procurement," of the Operating Quality Assurance Manual; SQA-45, " Quality Centrol of Materials, Parts, and Services," Sequeyah's site specific recuire-ments for procurement; and Seouoyah's Administrative Instruction AI-11, " Receipt Inspection, Handling, and Storage of 0A Materials, Substitutions and CA Level / Descriptions Changes."
A review of the definitions section of 50A-45 shows that TVA accu-rately reflected the !!RC's intent for the terms " basic component,"
" Class IE," and " commercial grade item," terms ccmmonly used when discussing procurement. Three other definitions of interest to the team were, " Level I Quality Assurance Material," and " Level II Quality Assuranc'e Material," commonly referred to as QA Level I -
and OA Level II, and " Critical Structures, Systems, and Components (CSSC)." A significant part of the problems discovered during this inspection stem from the definitions given for QA Level I and .0A Level II and their use. TVA's definitions for these terms - are as follows: . Level I Ouality Assurance Material--(1) Those CSSC materials, components, and spare parts which are a
'part of and whose failure would violate the reactor coolant pressure boundary; (2) these other CSSC items ~
that cannot be bought by industrial standards and reference part number; (3) certain items that must be specifically bought as Level I as required by Attachment 21 (reference DP N76A10) of this standard practice, and (4) electrical a equipment defined as Class IE. 4 I
'. ATTACHMENT G bE 16 of 35 Level II Quality Assurance--CSSC materials, components, and spare parts that can be purchased by positive identifica-C tion, provided that these items are not 0A Level I. 0A Level 11 permits in-kind replacement of items when the specified industry code or standard provides positive identification.
Pcsitive identification is established for an item by using one of the following methods:
- a. Documentation supplied wi.th the original equipment and/or from nameplate / tag information attached to the equipment.
- b. The item's description as specified by the engineering drawing bill of material, provided no special process is performed due to drawing notes, etc.
- c. The item's description as specified in the procurement technical specification.
- d. The item's noun name and part number when supplied by the original supplier, manufacturer, or vendor. .
These definitions are atypical of what is normal industry practice in that they describe what equipment falls into each category rather than describing the quality assurance requirements applicable to each category. Appendices to Attachment 20, " Specification of CA Program I Requiri:ments for Nuclear Power Requisitions," of SOA-45 contain the actual quality assurance requirements. These appendices are written for particular categories of eouipment, e.g., Appendix 1, "ASME Section.III-Materials;" Appendix 2, "ASME Section III Valves;" ! Appendix 5, " Class 1E Naterials and Equipment;" Appendix 8, "Non-ASME Code items Uhich .Have Unique Nuc' lear Requirements." A note which is pertinent to the findings of this inspection appears
' under the title of Appendix 8 as listed on paga 250 of the 7/12/82 -
versiqn of SQA-45. The note reads as follows: l ,
... Used for procurement of QA Levels I and II {10 CFR 21
. Applicable) basic components which have unique nuclear - '
7,,
' requirements, including Seismig Category I Application and equipment used in Class IE application [ device as a whole which requires qualification by supplier or j , manufacturer] which are not ASME Section III Code."
l A cursory reading of this note-by someone not familiar with TVA's . interpretation of the phrases "10 CFR 21 Applicable," " Seismic Category I Application," and " Class 1E application," would lead one to believe that electrical and non-ASME. mechanical equipment that was recuired to operate during and after a seismic event
, would be subject to the requirements of Appendix 8. However, as the next two paragraphs show, this is not the case.
./
5
'Y$17of35 d
. b ATTACHMENT G When TVA procedures discuss requirements for Seismic Cateoory I application and Class IE application, they are not necessarily (I referring to the specific pieces of equipment which must function during or after a seismic event. The statement, " device as a whcle which requires qualification by the supplier or manufacturer,"
appears in the note quoted above. As explained by TVA personnel during the inspection and as can be seen from the examples cited in paragraph 6.b. below, TVA personnel interpreted this to mean that seismic and 1E qualification was only applicable to the assembly qualified and supplied by the manufacturer. Therefore, if a "whole device" (e.g., motor control center, diesel generator set) was replaced, seismic qualification of the replacement was recuireo. However, if a subcomponent of the whole device was replaced (e.g., relay, circuit breaker, air starter motor) seismic oualification was not required for the replacement, regardless of whether or not The the replacement had to function during or af ter a seismic event. reason given for this practice was that TVA was crdering replacements by part number and was receiving an "in-kind" or "like-for-like" part. This practice was not adecuate to assure a qualified part, however, because the procurements were made OA Level II, no dccumentation required, which amounted to commercial grade and provided no assurance that the replacements were in fact "like-for-like." The procurement of safety-related equipment requiring seismic and environmental qualification as OA Level II occurred because of two problems. The second statement in the definition 0A Level I and the definition of QA Level 11 allcw items which can be identified by a unicue manufacturer's part number and are produced to . industry standards to be procured as OA Level II regardless of the safety function of the item or the industry standard invoked. The other problem is that rather than basing quality recuirements solely on the importance of the item being procured, TVA based cuality requirements on whether or not 10 CFR 21 was judged applicable tc ' the item. This problem was ccepounded by the fact that the form for determining Part'21 applicability, Attachment 11 to SQA-45, was biased - towar.ds not imposing Part 21 on anything less than a whole device. Therefore, a piece of equipment which was criginally supplied by the manufacturer as' seismically qualified could be replaced by a commercial grade item without appropriate engineering analysis because TVA's l.
- procedures allowed the equipment to be classified as QA Level II, Part 21 Not Applicable.
Paragraph 10.3 of ANSI N45.2.13 states that equipment may be accepted by source verification, receiving inspection, supplier certificate ~ j of conformance, post installation testing, or a combination thereof. As the examples in paragraph 6.b. show, TVA chose to accept eouipment l base don receiving inspection and post installation testing. The j .~ ' receiving inspecticn performed by TVA during the time period 1980-i 1984 consisted only of a check for shipping damage and cleanliness, and a comparison of the part number on the item to the ordered part number. Functional testing is performed after installation and assures that the piece of equipment will function during normal operation. However, receipt inspection and functional testing in-situ cannot 6 i 1-_ _ _
ATTACHMENT C l b 4 18 of 35
*! " j y validate the ability of.a piece of equipment to function during or f af ter a scismic event or exposure to a harsh environment. The other i methods of acceptance available to TVA were source verification and supplier certificate of conformance. The " source verification required" block and the " documentation required" block were marked N/A for all GA Level II procurements reviewed, although some manu-
. facturers submitted certificates of conformance (C of Cs) anyway.
However, in order to take credit for C of Cs, paragraph 10.2 of ANSI N45.2.13 requires that the purchaser have a means of verifying the validity of the C of C. The means' permitted by paragraph 10.2 are audits of the supplier or independent inspections or tests. While TVA performed independent inspections and tests, these tests could not be used to validate a C of C for seismic or environmental quali-fication since they only involved functional testing during normal operating conditions. TVA also performed audits of the suppliers of most of the equipment for which docilmentation packages were reviewed.
.However, a review of those audits indicates that the programs reviewed were the nuclear quality assurance programs and not the comercial grade programs. Pased on previous NRC vendor inspection experience, if the nuclear cuality assurance program is not invoked in the procurement document, the items being procured are usually not manufactured under the nuclear quality assurance program. Therefore, a C of C received based on a contract which invoked the commercial grade cuality program can only be considered valid if the commercial grade program has been audited and found acceptable, f
I b. Procurement Imolementation k The following describes the results of the review of MRs, procurement - documents, receipt inspection records, and other associated document-ation for selected equipment.
- 1) Steam Generator Level Solenoid Yalve (2-LSV-003-174):
MR A-593379 was issued on 12/2/85 to replace the coils in .
'ttis ASCO solenoid valve (model 206-381-ERVU) which provides a control function for the Main Steam isolation Valves. The
- valve being worked on, S/N 49243J-90, was en environmentally and seismically qualified valve, purchased under contract
- 80KJ3-00827551, which had imposed 10 CFR Part 21 and an .
Appendix B quality assurance program on the manufacturer. The valve location is the West Valve Room, a harsh environ-
' ment. Because of this, the maintenance was being contrclied under the Qualified Maintenance Data System (QMDS) and the -
MR was marked "QMD5" and "10 CFR 50.49 Device."
.- As stated above, the original scope of work was to replace the coils in this valve. However, because the craftsman could not remove the coil subassembly with the tools
" supplied for the ,iob, the whole valve was replaced with
. another fully qualified valve, S/N 84146H-C.
( 7
--...-. -. - - ___-.. _ - - _ . .0
.'.',, ( ATTACHMENT C F C 19 of 35
- If the craftsman had not encountered difficulty installing the replacement coils, the cualification of the original valve would have been indeterminate since the coils were procured as piecepcrts, OA Level II, no documentation required, and no review of the effect of the commercial grade coils on the seismic and environmental qualification of the original valve was made.
- 2) ,R eactor Trip Bypass Breaker B (2-BKRC-099-KH/319-G):
The undervoltage trip attachment (UVTA) on this Westinghouse DB-50 breaker was replaced under MR A-101112 on June 2a, 1985. The UVTA withdrawn from stock was one of 22 UVTAs purchased under contract 84P64-343921 in November 1983. The contract ~ identified the UVTAs as OA level. II, and did not impose OA, 10CFR21, seismic or documentation recuirements on the supplier. However, the supplier (Westinghouse) modified the original bid and self-imposeo 0A and 10CFR21 requirements. The microfilmed contract file at Sequoyah includes a Certificate of Qualification from Westinghouse for ten UVTAs, but only four of the ten listed correspond to the UVTAs delivered under contract 84P64-343921 and the UVTA installed on this breaker is not one of them. As there is no documentation to support qualification of the UVTA, the cualification of the breaker assembly is indeterminate.
- 3) Normal Feed Breaker to Reactor Vent Board 2B-B (2-BDC-201-J0-B):
( The Reactor Vent Board 2B-B was originally purchased with the I - 480V motor control centers under contract 71C2-54752, dated May 5, 1971. The contract requirec a cuality assurance program and seismic testing and qualification for the safety-related motor control centers listed on the contract. The seismic test report, dated March 1972, also documented successful separate testing of internal components, including a circuit interrupter of the type'specified for the motor control center feed breakers, . l t I Dn December 26, 1978, Purchase Requisition 272924 was issued to procure a replacement for the Reactor Vent Board 2B-B normal feed
. breaker and two additional overload trip units. The purchase -
' requisition and contract classified the items as OA level II, l - did not impose QA requirements on the supplier, did not recuire
' any quality documentation from the supplier, and determined that
,10CFR21 was not applicable to this procurement. The receiving inspection consisted of a ecmparison of nameplate data to the purchase documents. .
One of the two overload trip units was withdrawn from stock on l . September 8, 1979, and installed on the normal feed breaker for l the R'eactor Vent Board 2B-B under MR 00226. As there is no u documented evidence of qualification for the trip unit, it renders the qualification of the feed breaker and the safety-
. related motor control center it services indeterminate.
( U C
- . - _ . _ _ _ _ o
* *
- ATTACHMENT c AdE 20 of 35
- 4) Auxiliary Relay in 6.9kV Shutdown Logic Relay Cabinet 2A-A (2-Pt:LB-202-SC-A):
This safety-related logic cabinet was originally purchased in June 1972 under contract 72C02-83a03, which required a full CA program and seismic qualification. Contract 78P15-24576, dated September 29, 1979, purchased as OA level II,15 relays of various styles without imposing OA,10CFR21, seismic, or quality documentation requirements on the supplier.- One of the replacement relays was withdrawn from stock and l installed in the 6.9kV Shutdown Logic Relay Cabinet 2A-A under MR A-019533 on May 22, 1982. As there is no documented l evidence of qualification for the relay, it renders the cuali-fication of the safety-related. relay cabinet indeterminate. During research of the contract files for this panel, the origi-nal seismic report and additional correspondence was found to indicate problems with the seismic testing of two types of relays, including the type of relay replaced under MR A-019533. Al though a letter from TVA indicates acceptance of additional seismic testing of the relays, the report documenting the additional
- testing could not be located in the document control system during the three week period over which the inspection v:as conducted but was later obtained frcm an engineer who had retained a personal copy.
Boric Acid Transfer Pump Motor (2-MTRB-62-230-A): (f' 5) The original pump anc' motor assembly was supplied under the t'5SS contract with Westicghouse. The applicable Westinghouse speci-fication (677123 Pev.0) imposed seismic requirements for the assembly and reovired the supplier to provide documented proof of complit.nce to those requirements. Westinghouse provided Quality Release 11358-1, dated January 9,1974, as documentation -
.$ hat the boric acid transfer pump and motor assembly met the requirements of Specification 677123, Rev.0.
t
- . A replacement pur:p motor was purchased on January 13, 1982 under *~
contract 82P64-323717. Although TVA classifies the motor as ' ~ Class 1E, the contract identified the purchase as OA level II and did not impose QA, seismic,10CFR21, or documentation
. requirements on the vendor. A motor different than ordered was i supplied. A TVA substitution evaluation form (50t!P AI-11 Attachment 10, Appendix A Rev.10) was completed on August 9, ~
1982, but the engineering concurrence for Class 1E substitutions
*, was marked as not applicable. On January 13, 1983, the replste-ment motor was installed. As there is.no documentation to support qualification of the pump motor, the qualification of
'$ the pump motor assembly is indeterminate.
l i 9 , - n
\_, ATTACHMENT G L E 21 cf 35 . "* }
- 6) Diesel Generators:
The diesel generators were procured under contract 71061-92652 from Bruce-GM which required manufacturing under a 10 CFR 50, Appendix B ouality assurance program and seismic qualification of all equipment. Under RD-579489, dated 6/6/77, to contract 73223-65906, TVA procured replacement air starter _ motors from Ingersoll Rand as QA Level II, no documentation required. TVA has replaced these air starter motors numerous times either with motors procured from Ingersoll Rand or rebuilt by Sequoyah plant personnel. As there is no documentation to support qualification of the replacement or rebuilt air starter motors, the qualifi-cation of the air starter motors and the diesel generators in which they are installed is indeterminate.
- 7) Shutdown Board 2A-A Logic Relay ' Panel (2-BDA-202-CO-A):
Items selected by the inspection team during the plant walkdown included two Agastat time delay relays from this safety-related Class 1E panel. These were Agastat model number 7012PD relays, serial numbers (S/Hs) 81031110 and 80362242, and are in the control logic circuits for the essential raw cooling water and the component cooling water systems. The markings on these two relays indicate that they were not manuf actureo as qualified Class 1E components since the model number is not proceeded by an "E." This was subsequently confirmed with the relay manu-facturer, Amerace Corp. When contacted after completion of the inspection, Amerace Corp. indicated that the relays, S/fis 80362242 and 81031110, were manufactured commercial grade curing the thirty-sixth week of 1980 and the third week of 1981, respectively. Althcugh requested during the first week of the inspection, TVA was unable to identify or produce the procurement documents for these relays. However, since these relays are not uniquely
~
identified by TVA as Class IE devices, the inspection team - assumes that they were procured as piece parts, QA Level II, without the imposition of CA or documentation requirements on the supplier.
' As there is no documentation to support qualification of the
~
relays and the vendor's records indicate that they were not supplied as qualified devices, the qualification of the
. relays and shutdown board in which they are installed is indeterminate.
- 8) Containment Isolation Valve (2-FCV-32-103):
This air operated globe valve is required to close on a Class B ! isolation signal and is listed in Table 9.3.1-2 cf the FSAR as i a seismic category I valve. This valve was chosen during the
~ walk-through by the team to trace the procurement chain from
- an installed condition back to the documentation, and was also y included in the :: ample of items for which the maintenance history A
L i 10 l l L I
~-
ATIACHMENT G hd 22 cf 35
- was reviewed. The valve was ordered as an ASME Class 2 valve, I seismically cualified, under contract 73C34-83577, dated 3/15/73, from Masoneilan International Inc. The serial number of the
( ' installed valve, N00137-21-4, traces back to a valve data package - for valve PCV-32-103. However, a valve data ordering sheet could not be located fcr either PCV-37-103 or FCV-32-103 under contract 73C34-83577. A review of the maintenance history for this valve indicates that the valve failed its local leak rate test and was repaired under MR A-081510, dated 8/1/83. The MR indicates that the soft rubber seat had been damaged in service and was replaced. The seat was procured 0A Level II, no documentation required, under contract 79P14-278023 along with two other items. Because the seat was classified as QA Level .II, the receipt inspection did
~
not include characteristics such as material type, cure date, durometer standard, estimated shelf life and storage conditions, all of which should be verified for this type of material.
~
- 9) Control Valve (2-FSV-32-1031):
This ASCO solenoid valve, model 206-380-2RVU, serves a control function for air operated containment isolation valve 2-FCV-32-103 and is listed in Table 9.3.1-2 of the FSAR as a seismic category I valve. This valve was chosen during the walk-through by the team to try to trace from the installed condition back through the procurement chain to the documentation. The valve (serial [ number 68337K), was purchased under contract 82PK1-330545, dated
- k 4/8/82, from Mills & Lupton Supply Co. as CA Level II, no docu-mentation required. Also purcnased as QA Level II unter this ..
contract were replacement coils and repair kits for this model valve. Although no documentation was reouested and the reccipt inspection report for the valve had the " Certifying Document No." block marked "H/A," a Certificate of Compliance for the valve certifying its compliance to IEEE-323 and IEEE-344 was in the contract file.
- c. Conclusions Drawn from insoection Findinas
~
10 CFR 50, Appendix B, Criterion XVI requircs that conditions adverse
- to quality be promptly icentified and corrected. Hewever, although
! HSRS Report P.-84-17-HPS, dated March 12, 1985, pointed out that TVA was using commercial grade items as basic components without deter-mining the effect on the safety function of the component or system ' in which it was installed, TVA has not initiated an effort to identify - equipment which may be in nonconformance with seismic or environmental qualification requirements as a result of this practice. Sequoyah personnel have started a review of Class IE replacement devices for seismic qualification. However, the effect of usino commercial grade piece parts on seismically and environmentally quilified devices had not been considered at the time of the inspection. L l 11 j i L i
~
.- b ATTACHMENT G bdE 23 of 35 The method used by TVA to identify their sample of 50 devices resulted
[ in the majority of the sample being instrumentation items such as level, ( pressure, or temperature switches. TVA's selection process started with equipment identification numbers that were categori::ed as Class 1E, 10 CFR 50.49, or had a safety train desinnation. However, TVA's program only identifies "those devices qualified as a whole" as Class 1E and does not consider components or parts within a device as being Class 1E or affecting the qualification of the device. As a result, many safety-related electrical items such as circuit breakers, relays, and solenoid coils are not classified as 1E and therefore were not included in TVA's original sample. ! TVA management stated that they intended to look at the 238 MRs iden-tified as involving Class 1E device replacements rather than only the sample of 50 as originally intended. This would still not account for the piece part replacements for safety-related. electrical or mechanical equipment which comprise the majority of the replacements performec. The concerns identified above constitute examples which support Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Procurement Findings.
- 7. Record Retrievability At the start of the inspection approximately 30 components were identified by the inspectors during a plant walk-through to determine if the installed harcware was traceable back to the required procurement documents. This
.[( was in addition to the equipment documentation reouested as a result of the review of l'.Rs.
In eddition to examples 7.a and 7.b below, which involve record retrieva-bility, paragraphs 6.b.2), 6.b.4), 6.b.7), and 6.b.8) above provide examples of record retrievability in adoition to procurement problems. a) Residual Heat Reinoval Isolation Valve (2-FCV-74-1): MR A-10737, for the fabrication and installation of sixteen 1-3/4" x 8" bonnet studs, was issued 8/20/83. Although no procurement deficiencies were noted, a record retrieval or accuracy problem was identifiec. The MR required a visual examination of the studs. Inspection report R-0686, dated 8/20/83, referenced visual inspection procedure N-VT-1, Revision 4. During the course of the inspection this revision of the procedure was requested, but TVA was unable to produce i t. .
. ~~ b) Residual Heat Removal (RHR) Pump Motor (2-FMP-74-10):
MR A-080564, dated 3/15/83, requested that the 2A-A RHR pump motor shaf t material be verified. The method chosen to identify the shaft material was the application of a copper sulfate solution, which in combinaticn with visual observation, can be used in making a quali-
# tative decision as to whether the mcterial is carbon steel or stainless
( steel. Sequoyah Nuclear Power personnel performed the test and deter-mined that the material was stainless steei. 12 i
~
( ATTACHMENT G h.JE 24 of 35 Uhen the inspector requested the procedure for performing the test, ( TVA could not produce it. As a minimum, there should have been ( written instructions concerning the , strength of the copper sulfate solution, the length of time between application and evaluation, temperature of the material prior to application, method of appli-cation, and evaluation criteria. Several completed power Stores material receipt inspection packages that were ready to be micro-fisched were reviewed. The review revealed that some packages for safety-related components did not contain the required objective evidence of acceptability, i.e., manufacturer's Certificate of Conformances and the component functional test data sheets. Discussions with Division of Nuclear Engineering (DNE) personnel determined that separate organizational files of these documents were kept' by DNE. Therefore, several areas would have to be researched before the required objective evidence of acceptability for an item was available. As an example, package #839407, for eight nuclear grade Agastat tire delay relays.(Models E7012/E7022) procured by CNE, contained a closed OC inspection report that accepted the relays based on a handwritten note from DNE stating that DNE intended to accept the manufacturer's C of Cs. The reouired manufacturer's functional test data sheets were not in this package, but TVA personnel stated that the test data sheets were in a DNE file. When asked how the eouipment was controlled or tracked until DNE approved the C of Cs, Sequoyah personnel stated that
/ no additional controls were placed on the equipment and no tracking system existed. If DNE eventually decided that the C of Cs were not
( acceptable, the equipment may have already been installed. Similar examples were founo in package 838674 for four nuclear grade Foxboro differential pressure transmitters, and package E36394 for Atwood and l ! Morrill ASME Section III diese1; generator plug valves. The lack of objective evidence of acceptability in the closed procure-ment and receipt' inspection packages appears to have been caused by. the following items. (Items a) and b) were addressed in the NSRS - reports.) a). Failure to establish a procedure, including acccptance criteria,
'for closed package review to ensure that the necessary documents'
- are included in each package.
b) , Lack of adequate TVA organizational coordination, communication and/or procedures to provide one central focal point for review and storage of quality related documents. . c) Failure to establish a tracking system to assure receipt inspec-
.- tion packages eventually contain all necessary documentation or
- a reference to where the documentation is located.
l d) Failure to adeouately review and approve the completed GC inspection reports by the QC inspectors immediate management.
/
13
.0
' .b ,-
k ATIACHMENT G E 25 of 35 10 CFR 50, Appendix B, Criterion XVII requires that records be identi-f fiable and retrievable. ANSI N45.2.9, paragraph 6.2, reouires that records be retrievable without undue delay. However, records for (' installed equipment which do not have a unioue plant identification number (i.e., piece parts) could not be identified or retrieved during the three week' period between the time the inspection started and the i exit interview. Additionally, certain records could not be located through the record retrieval system and were located only by contacting an engineer in the Division of Nuclear Engineering who had a personal copy. This problem was previously identified in NSRS Reports I-83-13-PS and R-85-07-NPS and provides an additional example of TVA's failure to take adeouate corrective action to NSRS findinos. The concerns identified above contributed to Potential Enforcement Finding 50-327,328/86-61-01, Inadeouate Corrective Action to Previously Identified NSRS Procurement Findings.
- 8. Receiot Insoection Receipt inspection packages' for both past and present procurements and the associated versions of Administrative Instruction AI-11, " Receipt Inspection, Handling, and Storage of QA Materials, Substitutions, and 0A Level / Description Changes," were reviewed. . AI-11, Attachment 1,
" Materials Receipt Inspection Report," is a listino of types of inspec-tions such as shipping damage, markings, cleanliness, dimensional, electrical insulation, etc. , with three check-off columns, "Yes," "No,"
and "N/A." Paragraph 2.4 of AI-11 states that the inspector is respon-sible for determining which of the twenty inspection requirements apply. Paragraph 2.4.1 of AI-11 states that if any inspections in addition to the twenty listed are needed, the originator of the purchase request is respcnsible for preparing appropriate inspection instructions. However, AI-11 does not contain or reference any detailed inspection or test procedures which would tell receipt inspectors what dimensions or any other characteristic to check, what tools or eouipment should be used, or what the acceptance criteria are. The inspection report does not provide - - any space for recording the results of any inspections other than "Yes,"
"No," and "N/A."
10 CFR 50,' Appendix B, Criterion V, reovires that activities affecting
- quality be prescribed by documented instructions or procedures and include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily acccmplished. .
Contrary to the above, Sequoyah has not established detailed receipt inspection procedures which provide appropriate guidance to the receipt inspectors. This lack of instructions contributed to the problem
.* discussed in Section 7 of this report concerning closing of incomplete receipt incpection folders without a tracking system to assure that C of Cs are eventually approved.
l This problem was previously identified in NSRS Report R-84-1-17-NPS and prevides an aeditional example of TVA's failure to take adequate corrective [ action to NSRS findings. The concerns identified above contributed to Potential Enforcement Finding 50-327, 328/S6-61-01, Inadequate Corrective i ( Action to Previously Identified NSRS Findings. l 14
. - _ _ _ _ _ .s_ m
. . y've d ios.c-esi too.we.s.e s ATTACHMENT G { j 26 of 35
., *C UNITED STATES GOVERN 31ENT A02 861119 001
. Memorandum TENNESSEE VALLEY AUTHORITY '{
TO : Those listed .. . FROM : C. C. Mason, Acting Manager of Nuclear Power, LP 6N 36A-C DATE : HOV 2 41986
SUBJECT:
REPLACEMENT ITEMS TASK FORCE , Effective November 17, 1986, I am establishing a Replacement Items Task Force. The primary function of the Task Force is to develop and ensure implementation of a program to verify that seismic and environmental gualification of installed equipment has not been and will not be degraded. Specifically, the Task Force will develop measures to control future procurement, to control issuance of items currently in Power Stores, and to verify acceptability of installed items. A proposal for verification of installed items should be prepared for my approval by December 10. A rationale for the scope of work and a detailed schedule will be included. Procedures governing the verification and disposition of the findings must be developed prior to initiating work. A proposed program for current inventory and items procured prior to having a dedication program fully operable should be submitted by December 15. In parallel to this effort, a dedication program to govern future procurement should be implemented no later than January 31, 1987. r The attached flowcharts and the NuclearcRegulatory Commission letter from Taylor to White dated October 21, 1986, will provide guidance for the Task Force. Initially, the Replacement Items Task Force will consist of the following members: ... Division cf Nuclear Engineering Representative F. E. Dicola / ' -- e Replacement Items Program Manager, T. E. Spink f Financial and Planning Staff, C. R. McWherter Division of Nuclear Quality Assurance Representative. T. E. Spink TVA Purchasing Representative 5- b + , Division of Nuclear Safety and Licensing Representative- %H fd",c. Site Representative frem Sequoyah, Browns Ferry, and Watts Bar Nuclear Plants
) a.,fe c." g y,Mt ( .0, 1R
~For those organizations without named representatives, you should inform i
." 7. E. Spink of their designation. It is expected that many of the individuals who participated in the " piece parts" effort will serve on this Task Force.
A t&.e.1 hoa u . /jy. nua. . . y b -; ~ _ T; ;-- :J.u_L u C
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ATTACHMENT G PAC'E 27 of 35
*. , 2 Those listed .
. 7 g.
tt0V 2 419fE . REPLACEMENI ITEMS TASK FORCE Mr. DiCola should be made available at least half time for Task Force activities since the organizational lead for verification and dedication is the Division of Nuclear Engineering (DNE). . T. E. Spink will be a full-time program manager for this three-pronged effort and will be responsible for ensuring line organization and futureimplementation of the replacement items. approved measures for handling past, current, . T. E. Spink has authority'to obtain additional resources needed for support of For the duration of' the Task Force, T. E. Spink will the Task Force effort. report to R. W. Cantrell, Acting Director, DNE. h H. L. Abercrombie, ONP, Sequoyah F. E. DiCola, W12 A6 C-K l l R. V. Cantrell, W12 A12 C-K J. P. Darling, ONP, Bellefonte C. H. Fox, Jr., LP 6N 38A-C R. L. Gridley, LP SN 157B-C J. L. McAnally, LP SN 38A-C C. R. McWherter LP 3N 166B-C l R. C. Parker, LP AN 45A-C ' ' H. P. Pomrehn, Browns Ferry -
.T.E.Spink,LPAN58E-C(
' J. W. Thempson, E12 C31 C-K G. Toto, ONp, Watts Bar J. L. Villigms, Jr., 1700D CST 2-C TBJ:CLB Attachments . - cc (Attachments): RIMS, MR AN 72A-C (Re: A02 861023 019) R. C. Steffy, MR 6N 11B-C l G h e e m 1
, ' - D ATTACHMENT G I28of35
~.l~
Verify Acceptability of Installed Equipment . Determine Scope of Review of - Installation Documents 1
,, Accept As Is Disposition Rework Item Installation Test
& Evaluate Against Replace
- Restart Criteria Inspect
._5 Analyze i Develop Procedur.e -
for Review of Installation Documents Verify Acceptability of Items in Current Inventory I Determine Scope -- ,s of Review , Identify / 3 Segregate / l Control Issuaned Remove Items /
,- Reorder o
Develop Procedures for Assessing Current Invenstorv
- - - - ~
l_,. -. - _ - _ _ . _ . _ _ _ _
g . mgne z . .;,,, Estabitsh Establish Estab'11sh Establish "Ded!' cation" . Program to Inventory Storage Inventory Issue Installation Control Future Proc. Controls Controls Controls
?
Issue Develop and . Develop and Implement implement NQAM Pro:edure procedures procedures to (_ to assure assure that precured items !ssued I ssue dodication from Power Stores Site items are for use in safety-Implementing identifled as related app 11-Proc! dure g such and cations are > segregated from acceptable for " non-dedicated that use - h Develop Item (dedicated). 4
" Controlled ,.
o Commercial '
- Grade Items Implement Controls Llat" to assure that 575's contain all .,
necessary traceability @ Organi:;e and Staff Site Procurement references R{- n Engineering Function
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, ATTACilHENT 3 .-
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EVA.UATE [ 5 4 (non-comerc i n t tis LATION YES s ygg , 15 ITEtt 8' EVALUATE SH H DOCUtf EllTATIOff /v CotDfERCI AL IftPACT .110 ITEll CollTRACT CRADE 7 OCUtfENT 13 0 ,
, #10 YES
, DfPACT ; i i V % P bj ~
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UtfACCEPTABL b DOClfttENT l.OCATE C0f tfERCI AL CO TO C0tIDUCT EVAL UATlotP, . & CRADE b C,0ST g IDEtITIIT EDICATIOf
@ t:ALYSIS f30 :z:
tio Yes ACCEPTABLE H , o e , . . \/ l.0CATE, RE!!OVE ' -
.n AND MACE e *In 08 TA t ti 3 QUALIFICATIOli CUHE!IT S $
E, 9f YES , (Lt "
- ITElf QtfAl.IFIED
- 00CllllEtti & ( I I /
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- p*: , b 'iTTACHMEN'TG E 31 of 35
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** 'A 0 2 861023 UNITED STATES 019
~j fj NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
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..... October 21, 1985
~~
Docket Nos.: 50-327 . i and 50-328 l Tennessee Valley Authority ATTH: Mr. Steven A. White -
. Manager of Nuclear Power -
~
6N 38A Lookout Place - 4 1101 Market Place Chattanooga, Tennessee 37402-2801
--- Gentlemen:
.. A procurement and quality assurance records inspection at Sequoyah Nuclear Plant, Units 1 and 2, by the Office of Inspection and Enforcement was con-ducted September 15-19 and September 29-October 3,1986. The purpose of
- this inspection was to review Tennessee Valley Authority's (TVA) corrective action to Nuclear Safety Review Staff (HSRS) Reports R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS. .The inspection included a review of contracts for original and replacement equipment, maintenance requests, quality assurance program requirements, site procurement procedures and practices, and associated .
documentation. On October 3,1986, the inspection team met with Mr. H. L. Abercrombio and other members of your staff to discuss the inspection findings and observations to date. A summary of the more significant items identified
- and discussed during this meeting is enclosed.
l- Your attention is directed to the team's concern regarding the possible degra-dation of the seismic and environmental qualification of previously qualified equipment. Two, mechanisms through which this degradation can occur were ~ observed during the inspection: (1) replacement of previously qualified
" devices" with devices procured commercial grade without adequate dedication.
- l by TVA prior to placing the device in service (see Example 5 of Enclosure A) ~
i and (2) installing " piece parts" procured commercial grade in previously quali-fied devices without evaluating the effect of the piece part on the cualification - of the device or adequately dedicating the piece part (see Examples 1, 2, 3, 4, 6, and 7 of Enclosure A). The team is also concerned with TVA's inability to retrieve quality assurance records (see Examples 2, 7, and 8 of Enclosure A).
*The results of the inspection indicated that prior to the March 1986 revision of SQA-45, " Quality Control of Material, Parts, and Services'," a prograr:matic deficiency existed in TVA's procurement and use of replacement devices .and c piece parts for safety-rclated applications, particularly when seismic and
- environmental qualification was recuired. The team noted that Sequoyah personnel had started a review of Class 1E replacement devicee h"+ w aa'
/ nacElvcD ! -
p.tAnasooor.nNN. t OCT 231955
- uAucn. . or z.s
.. n e ors /("EARrG%~~.3 ,, *-
I
ATTACHMENT G I' . 32 of 35 N, , ,,* **y. 8. 9 "' y .- ~ Tennessee Valley Authority - 2- October 21, 1985 l ,. completed that review nor investigated the effect of piece part replacement on seismically or environmentally qualified equipment. In light of these findings and observations, we expect that appropriate measures will be taken h-to verify that the seismic and environmental qualification of installed equip-ment has not been degraded. Your corrective ~ action in this area, dedication . packages for commercial grade replacement devices already identified by TVA, and the implementation of the procurement-program described in the March 1986 revision of SQA-45 will be reviewed before plant startup.
. Additional detail on the enclosed procurement findings, along with the other ~
less significant findings, will be included-i.n the inspection report which will -- be issued in the near future. Sincerely. 79 As James M. Tay1 , Director 0 fice of In pection and Enforcement
Enclosure:
Procurement Inspection LQ5 e 6 $02S c291
. .g % -
OTFICE Cf UUCLEAR PC'.VER ' FINANCIAL ".J.N'C; met 6
.*. e CCI 27 '85
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- .*;.. '" "' ATTACHMENT C PAGE 33 of 35 Et!CLCSURE A SEQUOYAH NUCLEAR POWER PLANT UNITS 1 AND 2 ,
i ." PROCUREMENT INSPECTION . SEPTEMBER 15-19, 1986 SEPTEMBER 29-0CTOBER 3, 1986
. A. Procurement Findinas
. 1. Steam Generator Level Solenoid Valve (2-LSV-003-0174):
Maintenance Request (MR) A593379 was issued on 12/2/85 to replace the coils in this ASCO solenoid valve, which provides a control function for the Main Steam Isolation Valves. The MR was marked "QMD5" and "10 CFR 50.49 Device." The valve was a seismically and environmentally qualified valve, with cpmplete documentation, located in a harsh environment, the West Valve Room. Replacement coils, because they do not have a' unique plant identi-fication number, are considered " piece parts" by Tennessee Valley
. Authority (TVA) and are purchased 0A Level II, no documentation required. Replacing the coils in this valve would have degraded ~
- the previous qualification of this valve since TVA had no documen- -
tation or assurance that coils purchased commercial grade would continue to function during or af ter a seismic event and/or i exposure to a harsh environmenti Only the fact that craftsmen could not remove the coil subassembly with the tools supplied for the job and therefore replaced the - l
' valve with another qualified valve prevented th? degradation of instilled qualified equipment.
t i
- 2. Reactor Trio Bvoass Breaker B (2-BKRC-099-KH/319-G): ,
On contract 84P64.343921 TVA ordered undervoltage trip attachments l . (UVTAs) for the reactor trip bypass breaker as QA Level II, no documentation required, Part 21 not applicable. This was just af ter Generic Letter 83-28 was issued stating that the UVTAs were i to be considered safety-related,1E equipment. Fortunately, ' ' Westinghouse self-imposed an Appendix B quality assurance program which provided the controls necessary to maintain Class 1E quali-
- fication and provided documentation of that qualification.
$ On 6/24/85, under MRA-101112, TVA installed a UVTA (S/N 02YN212-64) on this breaker. However, UVTA (5/N 02YN212-64) is not listed on the Certification of Qualification received under the contract mentioned above, which was referenced on TVA's Form 575 associated -
with this maintenance request.
*8 ea I . -
l I - - . - . _ . - - - ._ . - . - - .
P
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ATTACHMENT G 34 of 35
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'l -
- 3. Reactor Vent Board 2B-B (2-BDC-201-J-0-B):
The original contract for the reactor vent board motor control centers ~ ' required manufacturing under an Appendix B quality assurance program and seismic qualification. On MR 00226, dated 12/18/78, TVA replaced an overload trip unit on the normal feed breaker, a IE breaker, for this vent board. The overload-4 rip units had been ' urchased as p . piece parts, QA Level II, no documentation required. i . 4. 6.9 KV Looic Relav Panel (2-PNLB-202-SC-A): , The original contract for the 6.9 KV logic relay panels required manufacturing under an Appendix B quality assurance program and seismic qualification. The panel and the relays were qualified i separately. On MR A-019533, completed 5/6/82, TVA replaced an ' auxiliary relay on the panel. The relay was purchased as a piece part, QA Level II, no documentation required, under contract 78P15-245756.
- 5. Boric Acid Transfer Pumo Motor (2-MTRS-62-230A):
The boric acid transfer pump motor was originally supplied under the NSSS contract. The specification required seismic qualification and Westinghouse supplied a Certificate of Qualification. On MR A-080011, dated 1/13/83, TVA replaced the motor with one purchased QA Level II,, no documentation required, under contract 82P64-323717. Because a different motor from the one ord.ered was supplied under the contract, TVA completed SQNP AI-11, Attachment 10, Appendix A. " Substitution Form," to document the review of the motor description change. However, engineering concurrence for Class 1E substitutions was marked "Not Applicable" and no additional documentation indicating whether a more detai. led review was performed could be located. .
- 6. Diesel Generators:
On the ' original contract for the diesel generators to Bruce-GM, contract l
#61-92652, the specification requires that all equipment be designed -
to withstand and operate after a seismic event and imposed an Appendix B quality assurance program on the vendor. On RD-579489, - dated 6/6/77, TVA ordered two air starter motors from Ingersoll Rand, QA Level II, no documentation required. These motors have been - a replaced many times under numerous MRs.
- 7. ~ Shutdown Board 2A-A Loaic Relav Panel (2-BDA-202-CO-A):
- As part of the inspection the team selected a number of items in the plant and tried to trace those items back through the procurement process. Two of the items selected were Agastat relays, model ~
I f7012PD, serial numbers (S/N) 81031110 and E0362242, located in snat-down board 2A-A. These relays are in the control logic circuits for l ( 4 e.. . ._, , _ ,
r~ , U. C PAGE 35 of 35
..';$;pk. ATTACHMENT G 'P ' '. I
- a . . .
the essential raw cooling water and the component cooling water . . , systems, respectively, which are IE safety-related functions. - Although requested during the first week of the inspection, TVA was not able to identify or produce the procurement documents for these relays. It should be noted that Amerace, the relay manu-f acturer,- indicates IE qualification and thatofthe their product relays bypanel in the preceeding were - the model number withAf anter "E"completing the inspection, the team - not marked as such. 81031110 and 80362242 - contacted Amerate and confirmed that relays were manufactured.as commercial g,rade, not IE, during the These third week of 1981 and the thirty-sixth . week of 1980, respectively. were probably procured QA Level II, no documen
~ B. RHR 1 solation Valve (2-FCV-74-1):
MR A-10737, dated 8/20/83, for the fabrication and installation of bonnet studs for this valve, indicate that a visual examination was perforced on 8/20/83 (Report !R-0686) in accordance with H-VT-1, Revision 4. course of the inspection but TVA was not able to produce it. t o , ,. p- , l - ( (
, )}}