ML19263B672
| ML19263B672 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263B662 | List: |
| References | |
| REF-QA-99900401 99900401-78-2, NUDOCS 7901220354 | |
| Download: ML19263B672 (3) | |
Text
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Combustion Engineering, Inc.
Docket No.
99900401/78-02 NOTICE OF DEVIATION Based on the results of a NRC inspection conducted on June 27-30, 1978, it appeared that certain of your activities were not conducted in full compliance with NRC commitments as indicated below:
A.
CE Topical CENPD-210-A, paragraph 17.10, states in part, ".
personnel perfoming surveillance activities are qualified to ANSI N45.2.6-1973...."
Procedure QAP 2.1 and its Appendix A, implements the requirements of ANSI N45.2.6 by requiring visual and NDE process certification and qualification (and periodic re-certification and re-qualification) for personnel performing surveillance activities.
Contrary to the above, the certifications and/or qualifications of at least four (4) individuals perfoming surveillance activities had expired and at least one individual had performed audits of NDE processes during the period that his NDE qualification was expired.
B.
CE Topical CENPD-210-A, paragraph 17.18, states in part, "The guidance of ANSI Standard Na5.2.12... are implemented by Group Quality Assurance and by management in their independent assessment of the effectiveness of the Power Systems Group Quality Assurance Program.
(See paragraph 17.2.6)."
Further, paragraph 17.5 states in part that, " Quality-related activities are documented through written operating procedures, Contrary to the above, management audits, prescribed in paragraph 17.2.6 of CENPD-210-A, are not documented through written operating procedures, consequently, the control and execution of these audits are not performed consistently.
(See inspection report DetailsSection II.C.3.a. for related comments.)
C.
Figure 17-5 of CE Topical CENPD-210-A identifies the internal audit responsiblities of Group Quality Systems (GQS) as being Manufacturing Services, Purchasing, Development, Engineering, Plant Apparatus, and Engineering (A.
t.
Contrary.to the above,. these internal audit responsibilities are not being' accomplishd, e.g., no GQS internal audits.have been
. conducted thus. far'in 1978, and Plant Aoparatus and:Cevelopment are
"" '" noti scheduled :to be audited in 1978.
(See inspection report, DetailsSection II.C.3.b. for related comn'ents. )
790122035V
. D.
10 CFR 50, Appendix B, Criterion III, Design Control, states in part, " Design control measures shall provide for verifying or checking the adequacy of design, such as by performance of design reviews... or by performar of a suitable testing program.
Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualification testing of a prototype unit under the most adverse design conditions."
Contrary to the above, the adequacy of the vendor design of motor-operated HPSI (High Pressure Safety Injection) valves procured by CE for five (5) nuclear plants does not appear to have been verified adequately. The valves for all five (5) plants were returr.ed to the vendor for design modification after questionable test results were cbserved at one site during pre-operational flow balancing tests. One licensee submitted a 50.55 (e) report relative to these valves.
(See Detail 5 Section III, paragraph 3, for additional information.)
E.
10 CFR 50, Appendix B, Criterion XV, Nonconforming Materials Parts or Components, states, " Measures shall be established 1o control materials, parts or components which do not confonn to requi ements
... Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in acccedance with documented procedures."
(See also Criterion XVI, Corrective Action.)
This requirement is implemented for one project by Nuclear Power Department - Methods and Procedures Instruction NPD-MPI-17, which states in part:
"B. Tne Field Action Request (FAR) will be prepared and submitted by Field Personnel to describe a nonconforming condition dis-covered in the field and to request resolution such as:
(1) Deviations from purchase order, contract, specifications or drawing requirements; (2) Inability of CE systems, equipment or material to meet requirements of installation, test or operating procedures or technical specifications....
"F. An FAR will be prepared by a C-E Windsor design group desiring to modify or change C-E furnished systems, equipment or material after delivery at the plant site."
. Contrary, to.the above, no FAR.was. generated by either..CE. sita u
w a
-m.t--
or CE-de' sign groups,' and. hence no established measuresuwere -
- a
" followed to documentureview or rework motor-operated -HPSI o.
re -.w m c ~ valves that-appearet. inadequate during pre-operational flow- -
o
. balancing tests at one plant.
HPSI valves were returned from the plant site to the vendor for modification without generation of an FAR.
F.
10 CFR 50, Appendix B, Criteria V, Instructions, Procedures and Drawings, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures and drawings...
and shall be accomplished in accordance with these instructions, procedures and drawings."
CE implementing procedure, QAP 8, Certification of Equipment, states in part:
"Before certification, the cognizant GQC Representatives shall
... assure t;.at all records required to date have been submitted to CE, chet ' with the supplier to assure the history, or records package 's complete... verify that properly completed and approved Deviation of Contract Requirements (DCR) is included in the records, if applicable... Resolve discrepancies:
"Exceptinns (Conditional) - If release is urgently required, a TWX (or equal) shall be received by the cognizant GQC Represen-tative via Purchasing or Production bearing ti.c names of the Project Manager, Engineering, and the GQC Superv. or indicating their approval to release the shipment... a copy of the TWX will be attached and referenced on the Certification."
Contrary to the above, approximately 20 Certifications of Equip-ment for P. O. 9403324 for Southern California Edison were signed by the GQC representative, releasing for shipment, without properly completed record packages (such as unapproved DCRs and test reports) and without the approval to release for shipment by the Project Manager, Engineering, and GQC Supervisor documented on a TWX (or equal).
.M