ML19341B930
| ML19341B930 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1980 |
| From: | Breaux D, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19341B919 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8102280184 | |
| Download: ML19341B930 (22) | |
Text
.
O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900400/80-04 Program No. 51100 Company:
The Babcock and Wilcox Company Nuclear Power Generation Division P. O. Box 1260 Lynchburg, Virginia 24505 Inspection Conducted:
November 3-7, 1980 t
Inspectors:
l2-!Y!
O D. F. Fox, Contractor Inspector Date Program Evaluation Section Vendor Inspection Branch
[
A D. G. Br
, I'ntpector/1 Date Program luation Section Vendor Inspection Branch i
[
bs
'b Approved by:
Cilief Date C. J. Hi 1 Program -
luation Section Vendor Icspection Branch Summary Inspection on November 3-7, 1980 (99900400/80-04)
Areas Inspected:
Implementation of Title 10 CFR 50, Appendix B, and Topical Report BAW-10096A including design document control, procurement source l
selection, product acceptance,' followup on NRC regional requests, and action on previous inspection findings.
The inspection involved sixty-five (65) inspector-hours on site by two (2) USNRC inspectors.
Results:
In the four (4) areas inspected, two (2) deviations from commitment were identified in one (1) of the areas.
Deviations:
Design Cocument Control - Design documents were not reviewed and approved in accordance with approved procedures.
(See Notice of Deviation, Item A) QA manual was not revised to reflect changes in organization, document effectivity and design control. (See Notice of Deviation, Item B).
810228 0lM
2 DETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contacted J. B. Andrews, Manager, Safety Analysis C. A. Armountrout, Manager, Audit Section T. L. Baldwin, Licensing Engineer T. A. Brandesberg, Manager, Mechanical Equipment W. T. Brunson, Principal Engineer, Fuel Design Control R. W. Colby, Engineer, Systems Engineering J. L. Davis, Manager, Data Administration
- E. V. DeCarli, Manager, Quality Assurance E. F. Dowling, Manager, Plant Protection Equipment F. R. Fahland, Manager, Component Engineering R. W. Farris, Manager, Fuel Design Control G. F. Glei, Manager, RCS Component Engineering R. A. King, Engineer, Fuel Structural Analysis
- D. E. Guilbert, Vice President, NPGD P. H. Hannell, Manager, Release Administration R. K. Kennedy, Manager, RCS Equipment R. D. McMahon, QA Manager, Bailey Meter Corporation (Telephone)
G. A. Meyer, Manager, Thermal and Hydraulics Engineering P. J. Motiska, Principal Engineer, QA
- D. H. Roy, Head, Engineering Department
- J. H. Taylor, Manager, Licensing L. A. Walton, Supervisor, Fuel Rod Group T. G. Wolcott, Supervisor, Control Monitoring and Display Equipment B.
Action on Previous Inspection Findings 1.
(Closed) Deviation A (Report 79-04):
A calculation did not include sources of design input, computer program names, versions and dates of runs.
The inspector verified the corrective action, generic consideration and preventive measures described in Babcock and Wilcox (B&W) letters of response dated February 26, 1980, May 1, 1980, and August 6, 1980.
Specifically: -(1) procedure NPGD-0402-01 (Processing of NPGD Prepared
' Calculations) was revised (Revision 11, dated September 2, 1980) to define the nature and extent of design inputs that must be referenced in each calculation package; (2) a schedule and priority was established for reviewing, and revising as necessary, existing NPGD safety related calculation packages that support FSAR's for active NSSS contracts; (3) training on the preparation and processing of calculations was oiven by the_ Engineering Department Manager on August 27, 1980, and (4),
the QA audit on November 3,.1980, of calculations being performed to the newly revised procedure revealed no discrepencies.
3 2.
(Closed) Deviation A (Report 80-02):
Committed corrective actions and preventive measures for previous inspection findings were not completed as scheduled.
The inspector verified the corrective action, and preventive measures described in B&W letters of response dated September 12, 1980, and November 6, 1980.
Specifically:
(1) NPGD Operating Instruction 01-1142 (Quality Assurance Audit Program) was revised (Revision 4 dated August 1, 1980) to incoroorate the ANSI N.45.2.12 requirements as committed; (2) Operating Instructions 0I-1037 and 01-1041 were superceded as committed; (3) NPGD QA will conduct audits of the Historical Document List (HDL) for completeness and accuracy within thirty (30) days after the completion of each phase (I and II) of the HDL Corrective Action Procram; and (4) NPGD QA has initiated a tracking and follow-up system to assure that management commitments in response to NRC inspection findings are timely and effectively implemented.
3.
(Closed) Deviation B (report 80-02):
CVARs (Contract Variation Approval Requests) were not categorized, reviewed, nor approved in accordance with procedures.
The inspector verified the corrective action and preventive measures described in B&W 1etters of response dated September 12, 1980, and November 6, 1980.
Specifically:
(1) Written instructions have been.
issued to clarify the intent of NPGD procedure NPG-0405-05 (Contract Variation Approval Request) to assure that CVAR's which result in design changes will receive the equivalent level of review and approval as the original design; and (2) NPGD procedure NPG-0405-05 was revised via an " Authorized Deviation Letter" dated November 5, 1980, to include the requirem mt that CVAR's which deviate from equipment and/or systcm design requirements are _ to be classified as Category 1 CVAR's and are to be reviewed by another qualified " hardware" enginaer.
4.
(Closed) Deviation C (Report 80-02):
The historical Document List (HDL) did not indicate the correct status of CVAR's.
The inspector verified the corrective action, generic consideration and the preventive measures described in B&W letter of response dated September 12, 1980.
Specifically:
(1) the status of all CVAR's con-tained in the HDL was revised (as necessary).to reflect the current status of the CVAR's; and (2) the CVAR form was revised on October 15, 1980, to provide for a clear indication of the " approval" or " disapproval" status of the CVAR.
5.
(Closed) Deviation D (Report 80-02):
PUL's (Product Upgrade List) were not prepared, approved, controlled, nor executed in accordance with procedures.
4 The inspector verified the corrective action, generic consideration and the preventive measures described B&W letter of response dated September 12, 1980.
Specifically:
(1) The IDRP (Illegable Document Review Program) " Task Force" established by NPGD to upgrade the legi-bility and accuracy of past (and current) QA records as a result of Deviation A in Report 80-01 identified the status of all outstanding PUL's; (2) B&W Memorandums " Processing of Product Upgrade Lists (PUL)"
dated September 22, 1980, " Document Illegibility Repair - HDL Update -
PUL Correction Program" dated October 27, 1980, "PUL Corrective Action Program" dated November 4, 1980, and " Clarification of NPGD Administrative Procedure" dated November 5, 1980, expand on the requirements of NPGD procedure NPG-0412-66 (Release of Product Documentation) and provide for:
an overall plan of action with specific responsibilities assigned for the correction of the deficiencies indicated in Report 80-02 as well as with all other open PUL's; serialization of all PUL's; identification of the original document update point of PUL's; PUL change control by Release Administration; resolving of outstanding PUL items by the identified original document update point; the assessment of the impact of open PULs on past and current procurement activities; and clear identification of the existance of an open PUL (Y = yes, N = no) on the applicable Document Lists (ADL) for NPGD designed / procured items; and (3) NPGD procedure NPG-0412-66 was revised via an " Authorized Deviation Letter" dated November 5, 1980.
y 6.
(Closed) Follow up Item (Report 80-02,Section II.C.3.d):
Status of PUL's-against procurement documents is unclear on the ADL; PUL's may not have been cleared prior to procurement acticn.
The concerns identified in this follow-up item were addressed by B&W as part of their corrective action, generic consideration and preven-tive measures for Deviation D (Report 80-02) above.
C.
Regional Request (Instrumentation and Control (I&C) Faiiure Due to Improper Insertion of Buffer Cards in Buffer Modules)
===1.
Background===
Improper insertion of a buffer card (printed circuit board) in.a
- buffer (isolation) module used in a non-nuclear instrumentation (NNI) system subsequently resulted in a reactor trip and a dis-
-charge of primary coolant into the containment of the Florida Power Corporation (FPC) Crystal River Unit 3 (CR-3) Nuclear Generating Plant.
5 The Tennessee Valley Authority e.1d Vepco subsequently submitted 10 CFR 50.55(e)/10 CFR 21 reports on July 31, 1980, and August 1, 1980, expresing concern that a similar incident could result from a failure of buffers in the Essential Control Instrumentation Systems of their B&W designed nuclear steam supply systems.
2.
Oojemtives The objectives of this area of the inspection were to verify that:
The available information and documentation are complete and a.
accurate.
b.
The cause and effect of the incident were accurately identified, evaluated and documented.
The corrective action taken and preventive measures are being c.
planned or implemented.
d.
The generic aspects have been considered and affected organizations have been notified.
3.
Methods of Accomplishment The preceding objectives were accomplished by review of the following.
a.
IE Information Notice 80-10 (Partial loss of Non-Nuclear Instrument System Power Supply During Operation) dated March 7, 1980, to determine the cause and effect of improper insertion of buffer cards in buffer modules supplied by the Baily Control Company (BCCo) for the B&W designed FPC CR-3 nuclear steam supply system (NSSS).
b.
B&W Preliminary Safety Concern 32-80 (Improper Insertion of Buffer Cards) dated March 13, 1980, to evaluate B&W's initial considerations of the potential generic aspects of the FPC CR-3 incident.
c.
NRC letter (Final Report of the B&W Transient Response Task Force) dated Pay 1, 1980, to determine the recommendations made by NRC with respect to providing more reliable instrumentation and control systems for B&W designed NSSS systems.
d.
NUREG-0667 (Transient Response of Babcock and Wilcox Designed Reactors) dated May 1980,.to determine those instrumentation and control systems in plants with B&W NSSS systems, other than the NNI system, which utilize BCCo buffer modules, the failure of which could result in an incident similar to that which occurred at FPC CR-3.
6 B&W 10 CFR Part 21 to I&E Headquarters dated July 18, 1980, to e.
determine that B&W had evaluated and reported all users (or would be users) of the BCCo buffer module.
f.
Preliminary non propriatory version of the final report of the
" Crystal River Unit 3 Nuclear Safety Review Task Force" dated July 28, 1980, to determine the conclusions reached by FPC with respect to product improvement, modifications of procedures, reinforcement of training, and others, relating to the FPC systems deploying the BCCo buffer modules.
g.
BCCo 1978-79 General Product Catalog and Product Instructions IE92-79-171 (Original),E92-79 (Revised) for buffer modules and associated buffer component cards to de,termine the functions, specifications, identification coding and physical arrangement of buffer modules and components provided by BCCo in their 820 series Instrumentation and Control System product line.
h.
Drawings and specifications of b *fer modules and components:
08058470G - Legend and Drawing Reference t
08058484F - Secondary Plant System E1306-1274 - Module Arrangement List i.
BCCo Buffer Module (Part No. 6624610A1H, SN#178317, mraufactured July 10, 1978) and Voltage Output Converter Card (Part No.
6626747G1, SN#8779) to physically verify the possible ways that buffer cards could be improperly inserted into a buffer module and to determine that the corrective action and preventive measures taken by B&W and BCCo will provide assurance against an occurance of an event similar to the FPC CR-3 type incident.
j.
Numerous B&W letters, memos, technical evaluations, safety concerns, and " User Group" commurications and summaries thereof, to determine if the identified caase and effect of the original FPC CR-3 incident, generic consideration, and corrective and preventive measures, were accurate, complete, and documented.
3.
Findings a.
Deviations'. Unresolved Items and Followuo Items None identified, b.
Comments (1)
Improper insertion of an input buffer caid in a Bailey Controls Company buffer module by Florida Power Corporation maintenance personnel has been tenatively identified as
7 causing a short circuit between the +24 volt NNI power supply and ground.
The short circuit initiated a sequence of events which resulted in a reactor trip and an inadvertant discharge of primary coolant into the containment of the Crystal River Unit 3 nuclear generating station.
Although the circumstances which resulted in th: misinsertion of the module were not fully determined, Babcock & Wilcox concluded that it was possible to interpret a statement in the Bailey Control Company Instruction Book for the buffer module to mean that input buffer cards may be replaced with-out removing the buffer module from the instrumentation and control panel and that during field changes it was possible to improperly install at least one card in both of the power channels which could result in the loss of power to both instrumentation and control channels.
The instruction book was revised by the Bailey Control Company to eliminate ambiguities and to provide detailed instructions for installation of the cards in buffer modules.
The revised instruction book has been, or will be transmitted by B&W to all of their affected customers.
Based on direct observation, review of documentatic.1 and product made available to the inspector during the inspic-tion, and personal interviews and telephone conversations with responsible B&W and BCCo management conducted during the inspection, it appears that objectives (a) through (d) above were accomplished and that B&W acted responsively and responsibily to this incident.
Specifically, the B&W participation in the identification of the cause and effect of the original FPC CR-3 incident, their identification of a safety concern and the subsequent reporting of it to NRC and to all affected B&W customers (Users Group), their evaluation of generic considerations, and the corrective and preventive measures taken by 8&W, were accurate, timely, complete, and documented except that revised lastrument Instruction Manual (s) have not yet been transmitted to:
Washington Public Power System (WNP 1/4 - ECI, ICS and NNI Systems) - Manual in nrocess.
Toledo Edison (Davis Besse - Aux. Panel, ICS and NNI Systems) -
Scheduled for November 14, 1980.
Arkansas Power & Light (ANO 1-ESFAS, ICS and NNI Systems) -
Scheduled for November 14, 1080.
8 (2) Additional Information (a) Cause and Effect of the FPC CR-3 incident.
On February 26, 1980, with FPC CR-3 at 100% power a +24 volt power suoply to the NNI was lost due to a short to ground (in a ouffer module).
This resulted in a reactor and turbine trip and initiated a sequence of events wherein the Power Operated Relief Valve (PORV) opened and stayed open as a direct result of the NNI power upply loss.
High Pressure Injection (HPI) initiated as a result of depressurization through the open PORV, and with af, proximately 70% of NNI inoperable or inaccurate, the operator correctly decided that there was insufficient inform;_ tion available to justify terminating HPI.
There-fare, the pressurizer was pumped solid, one safety valve lifted, and flow through the safety valve was sufficient to rupture the Reactor Coolant Drain Tank rupture disk, spilling approximately forty-three thousand gallons of pri. nary water into containment.
The FPC CR-3 event is closely related to the November 10, 1979 event at Oconee Unit 3 wherein the inverter supply-ing power to the Integrated Control System (ICS) and to parts of the NNI failed.
The CR-3 event involved loss of only part of the power available from an inverter, rather than the inverter itself, since the +24v supply is only one of several power supplies drawing power from one inverter.
The effects are very similar, however, in that the ICS lost part of its input signals in both events.
The cause of the +24 volt power supply short to ground was tentatively it antified to have occurred between the knife like edge co.'nectors of a Bailey Control Company Voltage Buffer Caro.
The voltage buffer card was allegedly misaligned in its receptacle, and adjacent connectors carrying +24v and " common" were bent such that they contacted one another.
This short circuit cleared itself during subsequent _re-energizing of the power supply by burning through the foil on printed circuit card.
Subsequent investigations identified a second voltage buffer card which was also misaligned but had not caused a short circuit.
(b) B&W Supolied Equioment Containing One or More BCCo Buffer Modules
~~
9 (i) Arkansas Power & Light, ANO-1:E.cFAS nuclear safety system, and the ICS (Integrated Control System) and NNI (non-nuclear Instrumentation) non-nuclear safety systems.
(ii) Florida Power Corporation, CR-3:ICS and *!NI systems.
(iii) Portland General Electric, Pebbles Spring:ECI (Essential Control Instrumentatisn) nuclear safety system, and the ICS and NNI systems.
(iv) Sacramento Municipal Utility District, Rancno Seco:
(v) Tennessee Valley Authority, Bellefonte:ECI, ICS, and NNI systems.
(vi) Toledo Edison, Davis 8t;se: Auxiliary Shut Down Panel nuclear safety system and the ICS and NNI systems.
(vii? Virginia Electric Power Company, North Anna 3 & 4:
(viii) Washington Public Power Supply System, WNP 1 & 4:
(c) Other Users of BCCo_ Buffer Modules _
The inspector could not determine during this inspection of B&W:
(1) if nuclear power generating stations, with NSSS systems not supplied by B&W, utilize any BCCo buffer modules in-their safety related instrumentation and control systems; (2) action has been taken by BCCo to identify owners of such equipment and to appraise them of.the cor-rective action and preventive measures to prevent the occurance of an event similar to the CR-3 incident.
(d)
Potential Misinsertions of Buffer Cards in Buffer Modules and Methods for Preventing / Detecting Same.
(i)
Insertion of a buffer. card into buffer module while the system is energized (powered).
Maintenance personnel must' comply with maintenance instructions given on page 8 of BCCo Product Instruction (PI) E92-79 (Euffer Module) or equi-valent.
System must be deenergized.
10 (ii)
Insertions of a buffer card into the wrong one of tha four card slots in the buffer module.
Maintenance personnel must be aware of the location codes given on page 2 of PI E92-79 and Plant / System -
specific module arrangement lists and legend / drawing reference lists.
(iii) Misalignment of the closely dimensioned electrical contacts on the buffer card with the mating contacts in the buffer module.
Maintenance personnel must follow the module inser-tion and visual checking instructions given on page 8 of PI E92-79.
(iv)
Insertion of a buffer card backwards into a card slot.
Maintenance personnel must follow the module inser-tion and visual checking instructions given on page 8 of PI E92-79.
Furthermore, the front cover of the buffer module cannot be 2placed without knowingly forcing / bending the contacts on either the buffer card or the mating ones in the module.
(v)
Insertion of a buffer card with the wrong side of the card up.
Voltage buffer cards, current buffer cards, and voltage output converter cards cannot be physically inserted into the buffer module ir. this manner unless both side edges of the card were not inserted into the card edge tracks.
However, there is a remote possibility that a voltage divider board, with its smaller electrical components, could know-ingly be forced into a buffer module in this manner by inserting the leading edges of the card into the card edge guides, bowing the card, and forcing it into the module.
A'.; hough the module insr tion instructions given on page 8 of PI E92-79 do not specifically identify the orientation of a card with respect to the vertical center plane of the module when it is being inserted, the voltage divider board could not be misoriented without knowingly expending abnormal force throughout the entire time it is being inserted into the module.
11 (vi) Buffer cards can be misinserted into the module with one edge of the cara properly held in one of the card edge guides and the other edge of the card siding on top of the other guide in the module.
The contacts on the card would partially engage with the contacts in the module and physically hold
-the card.
Maintenance personnel must assure that both edges of the card are started into the corre-sponding module tracks and follow the module insertion and visual checking instructions given on page 8 of PI E92-79.
(vii) Buffer cards can be misinserted into the module with neither edge of the card in the card edge tracks.
However, the card will not remain in place when the module is moved about.
Maintenance personnel must assure that both edges of the card are started into the corresponding module tracks and follow the module insertion and visual checking instructions given on page 8 of PI E92-79.
D.
Design Document Control 1.
Objectives To determine if approved procedures have been established and are being implemented for the control and distribution of design documents that provide for:
Identification of personnel positions or organizations responsible a.
for preparing, reviewing, approving, and istuing design documents.
t.
Identification of the proper documents to be used in performing the design, c.
Coordination and control of design (inte nal and external) inter-face documents.
d.
. Ascertaining that proper documents, and revisions thereto, are accessible and are being used.
e.
Establishing distribution lists which are updated and maintained current.
2.
Methods of Accomolishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine.it procedures have been established to control design document generation, review, approval, and distribution, in the areas identified in objectives a. through e. above:
12 (1) Sections 3.0, 5.0, and 6.0, of the NRC accepted B&W Topical Report BAW-10096A (Quality Program for Nuclear Equipment)
Revision 3 dated April 18, 1977, to determine the B&W corp-orate programmatic commitments relative to the control of design documents.
(2) Sections 0, 1, 2, 3, 5 and 6 of the B&W NPGD (Nuclear Power Generation Division) Quality Assurance Manual No.
19A-N-1 to determine if the corporate commitments relative to control of design documents were correctly translated into quali'.y assurance requirements and procedures.
(3) The following procedures contained n the NPGD Administration Manual to determine that the NPGD quality assurance program requirements and procedures were correctly translated into a viable engineering program for control of design documents:
09-1212 NPG-0405-21 NPG-0412-58 NPG-0402-01 NPG-0412-55 NPG-0412-66 NPG-0403-11 NPG-0412-56 NPG-0503-07 NPG-0405-05 NPG-0412-57 NPG-1702-09 (4) Authorized Deviation Letter " Deviation From Administrative Procedures - Engineering Department Reorganization" dated February 12, 1980, to determine approved deviations from procedural requirements.
b.
The following documents were reviewed to determine if the quality assurance program for control of design documents was being effec-tively implemented on current design activities affecting quality by the B&W engineering organizations:
Three (3) Applicable Documents Lists, Eight (8) Calculations, Two (2) Change Inquiry / Authorization, One (1) Contract Variation Approval Requests, Two (2) Drawings, Four (4) Field Change / Authorizations, Two (2) Procurement Authorizations, Two (2) Quality Requirements Matrix, Two (2) Reports, Four (4)-Specifications, and One (1) System Specification.
a 13 3.
Findings a.
Deviations from Commitment Two (2) deviations from commitment were identified in this area of the inspection.
See Notice of Deviation.
(1) With respect to Deviation A:
(a) Authroized deviation letter " Deviation From Administra-tive Procedures - Engineering Department Reorganization" dated February 12, 1980, was issued by the Vice President of B&W NPGD to accomodate for one year the realignment of organizational responsibilities within the Engineering Jepartment resulting from the mid January 1980 reorgan-ization of the Engineering Department.
The subsequent (July 15, 1980) reorganization of NPGD's eleven depart-ments into seven departments did not impact on the scope or intent of the above deviation letter (memo).
The stated purpose of the deviation letter "... is to delineate (engineering and procurement) docuniant prepara-tion, approval and review responsibilities pending the modification of existing procedures to reflect these organizational changes.
The necessary changes to the procedures will be made within one year of the date of this letter."
The deviation letter further states that "It is important that all engineering work continue in an orderly manner after the reorganization.
It will no longer be possible to process engineering documents in strict accordance with existing procedures.
Therefore, in order to insure continued smooth flow of such documentation, the reviews and approvals (for the forty-eight) types or classes of documents) described in the attachment will replace those specified in the procedures."
(Note, the reqaire-ments for the preparation, review and approval of calcu-lations was apparently inadvertantly omitted from the list of documents attached to the deviation letter).
The deviation letter does not discriminate between the preparer, reviewer and approver signature requirements on the lead sheets and the continuation sheets (if any) of the documents.
This lack of discrimination apparently resulted in inconsistancies between the deviation letter and the residual procedural requirements and nonuniform interpretation and appl: cation of the "cocrdinated" requirements.
14 (b) Specific preparation, review and approval requirements and deviations therefrom observed in the thirty one (31) documents examined during the inspection are as follows.
The lead sheet / approval page of the one examined Manufacturing Specification did not exhibit evidence of the required review action by the reviewing
" Hardware Engineer From the Originators Unit" (Lack of signatory on the lead sheet / approval page of 27-1117470, revision 3, dated October 20, 1980).
The lead sheet / approval page of one of three examined Applicable Document Lists did not exhibit evidence of the required review and approval actions by the reviewing " Hardware Engineer From the Origin-ators Unit" nor the " Unit Manager of Originating Unit" (Lack of signatories on the lead sheet / approval page of 21-1101412, revision 0, dated April 29, 1980).
The lead sheet / approval page of three (3) of four (4) examined Field Change Authorizations did not exhibit evidence of the required review action by the reviewing " Cognizant Engineer From the Origin-ators Unit" and on one of the three (3), approval action -by the " Unit Manager of Originating Unit" (Lack of signatories on the lead sheet / approval page of: 04-3370, revision 0, dated October 22, 1980; 04-3387, revision 0, dated September 25, 1980; and 04-3396, revision 0, dated October 21, 1980).
(c) An in-depth technical review of the five (5) documents lacking the' required signatures revealed no apparent evidence of technical inadequacy in the content of the documents.
However, nonuniform interpretation and application of the requirements for review and approval of design documents is considered to present a finite
~ potential for'an.inadvertant error to occur in a design and for.it to be promulgated across design interfaces without detection.
(2) With respect to_ Deviation 8:
4 (a) -Section VI of procedure NPG-1702-09 (Preparation / Review /
Approval of QA Manual) states in part "The 19A-N.1 QA Manual...' shall be revised at intervals indicated in the manual.
Manuals shall-be revised as needed." -
15 (b) Section 6 (Document Control) of the QA Manual states in part that " Preparation, revision, and distribution of the Quality Assurance Manual is in accordance with the method described in the introductions to this manual."
(c) The Introduction to the QA Manual states in part that "The Manager of QA Engineering, or his designee shall be responsible for the preparation, maintenance and revisions of this manual."
(d) Section 6 (Document Control) of the 19A-N.1 QA Manual states in part that " Policies, procedures (including QA procedures which collectively constitute the QA Manual) and instructions are controlled by the Policies, Systems and Procedures (PS&P) Unit to ensure prompt inclusion of changes to these and related documents and to ensure proper control of obsolete or superceded documents to prevent their inadvertent use."
(e) The 19A-N.1 QA Manual does not specifically indicate the intervals at which the manual shall be reviewed for conformance to the in place Quality Assurance and Engineering Organizations, realignment of organizational functions and responsibilities, preparation, review and approval requirements for design and procurement documents, design interface control, and references to supercec d or obsoleted documents, that resulted from organizational changes made in mid January 1980 and in mid July 1980.
However, the manual, and implementing procedures, clearly require that:
(i) The QA Manual shall be revised as needed.
See (a) above.
(ii)
The QA Manual shall be promptly revised to ensure against the inadvertent use of superceded or obsolete documents.
See (d) above.
(iii) The QA Manual shall assure " Coordination of external and internal interfaces among participating design organizations (which is ensured by procedures which address review, approval, release, and distribution of the documents used to develop the design."
See Section 3, of the QA Manual and related Deviation A above.
16 (iv) " Quality Assurance Engineering reviews the QA Manual upon receipt of Code Addenda (normally every six months)... Approved changes will be incorp-orated in the manual within six (6) months from the date of issue of the code addenda."
See Section 4 of the QA Manual.
(f) The current revision of the 19A-N.1 QA Manual:
(i) Was not revised as needed.
Specifically, the QA MaAual was not revised since 1979 even though the Quality Assurance and Engineering departments were reorganized in early 1980.
(ii) Does not ensure against the use of superceded or obsolete documents, i.e., System Requirements Specifications document is an obsolete document but still defined and referenced in the QA Manual.
(iii) Dses not assure coordination of design interfaces since it does not properly identify the current design organizations nor their responsibilities.
e (iv) Does not reflect the current preparation, review and approval requirements for design and procure-ment documents.
(v) Was not promptly revised to reflect organizational realignments of functions and responsibilities made in mid January, 1980 and mid July, 1980, b.
Unresolved and Followuo Items None were identified.
.E.
Exit Meeting An exit meeting was conducted with Babcock and Wilcox NPGD personnel indi-cated by an asterisk in the Details Sections of this report at the conclusion of the inspection on November 7, 1980.
-The inspector discussed the scope of th inspection and the details of the findings identified during the inspection.
Management requested additional details on the findings and stated that an in-depth evaluation of the
. procedures and approved deviation letters controlling the generation, review, approval, issue, and implementation of design documents would be performed to determine the cause, extent, and significance of the apparent inconsistancies and nonuniform interpretation and application of procedural
~
requirements.
Management further stated that the evaluation will be completed and action will-be taken to assure that the governing in place procedures and manuals are. definitive and that they are being uniformly and effectively implemented by all affected quality and engineering personnel.
17 DETAILS SECTION II (Prepared by D. G. Breaux)
A.
Persons Contacted C. A. Armontrout, Manager, QA Audits G. P. Bennett, Purchasing Senior Buyer T. J. Morgan, Documentation Coordinator P. G. Perry, Manager, QC Surveillance B. A. Puett, MPC Materials Buyer Procurement Source Selection 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for the selection of qualified suppliers of services, materials, parts and components that provide for:
a.
Requirements for evaluatira of the potential supplier's capability to provide items or services in accordance with the technical and quality assurance specifications of the procurement documents, b.
Methods of evaluating potential suppliers that are consistent with applicable regulatory, code and contract requirements and should include source evaluation audits, review of historical performance, and/or review and evaluation of the supplier's QA program, manual and procedures.
Consideration of the complexity, inspectability and safety signifi-c.
cance of purchased items or services when selecting the method of source evaluation, d.
Performance of source evaluation audits that include appropriate checklists or instructions for systematic review of the prospec-tive supplier's QA system.
e.
Qualification requirements for personnel performing source evalu-ation audits.
f.
Source selection being based on historical prod"ct performance that includes review of'past procurement and operating experience with identical or similar items and.is limited to relatively sinple services or off-the-shelf items.
L
~
18 g.
Periodic re-evaluation of suppliers and that an up-to-date listing of the evaluation status is being maintained.
h.
Distribution of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to companies desig-nated in these documents, i.
Measures to assure that the supplier's bid conforms to the procure-ment document requirements and that resolution of unacceptable conditions identified during bid evaluation are corrected before the contract award.
2.
Method of Accomplishment The~prec1 ding objectives were accomplished by an examination of the following documents:
a.
The bases of' Procurement Source Selection were identified in Babcock & Wilcox NPGD Quality Assurance Manual QAM 19A-N-1 Section 7 titled " Control of Purchased Material Equipment, and Services,"
paraoraph 3.0 entitled " Supplier Selection." The organizations invo.ved, along with their specific duties delegated to them for performing the function of Procurement Source Selection have been identified in this section.
b.
The following Babcock and Wilcox Nuclear Power Generation Division Procedures (NPGD) were reviewed for a more specific view of QA role in Procurement Source Selection.
(1) NPG-1708-08, "QC Surveillance" (2) NPG-0412-66, " Release of Product Documentation" (3) NPG-1703-01, " Preparation and Processing of Internal Deficiency Report / Restraint Order / Corrective Action Request."
(4) NPG-1705-03, " Preparation and Processing of Quality Assurance Data Packages and-NPGD Certificate of Conformance."
c.
The following'NPGD Operating Instructions were reviewed for consistancy with respect to the guidelines of the Quality Assurance Manual:
(1) '0I-1000 Revision 3, " Review of QA Data Packages."
(2) 01-1142 Revision 4, " Quality Assurance Audit Program."
m.
19 d.
A QA generated document entitled " Supplier Status List (SSL)"
dated October 11, 1980, was reviewed to assure procedural imple-mentation.
e.
Babcock and Wilcox Quality Assurance Supplier Audit Schedule dated October 1, 1980, was reviewed to assure that procedures were implemented properly.
f.
From the two afforementioned lists the following pre / award and periodic reevaluation audit reports were reviewed for propei coi; tent and verification:
(1) (Periodic); Supplier: Aloyco, Linden, N. J.
QA Audit Report 79-3 dated April 18, 1979.
.(2) (Periodic); Supplier:
Bingham Willamette, Portland, Oregon.
(3)
(Periodic); Supplier:
UAP Components, Columbia S. C.
(4) -(Preaward); Supplier:
Iomics, Inc, Bridgeville, P.-A.
QA audit Report 80-09.
-(5)
(Preaward); Supplier:
Mercury Co. Brockton, Massachusetts QA Audit Report 80-01.
g.
Two (2) procurement. packages were reviewed for examples of preaward evaluations such as " Supplier Quote Technical Evalua-tion," end " Vendor Bid Technical Evaluations."
h.
Five (5) Document Comment Forms which evidenced Supplier QA Manual Approval were reviewed for proper procedural imple-mentation.
i.
Five (5) Procurement Authorization and Inquiry to Suppliers for bids were reviewed for content and approval.
j.
Five (5) Audit. Item Reports were reviewed for proper content and approval.
3.
Findings Deviations From Commitment, Unresolved Items, and Followuo Items None were identified.
20 B.
Product Acceptance 1.
Objectives The objectives of this area of the inspection were the following:
To ascertain that procedures have been prepared and approved by a.
the company to prescribe a system for product acceptance which is consistent with the commitments of the QA Program.
b.
To determine that the procedures for product acceptance are being properly and effectively implemented by the company.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of the following documents:
a.
Product Acceptance was identified in certain Sections of the Babcock and Wilcox NPGD Quality Assurance Manual QAM 19A-N.1.
The organizations involved, along with their specific duties delegated to=them for performing Product Acceptance have been identified in these sections.
b.
The following NPGD procedures were reviewed for a more specific view of QA role in product acceptance.
(1) NPG-1708-08 "QC Surveillance" (2) NPG-0412-66 " Release of Product Documentation" (3) NPG-1705-03 " Preparation and Processing of Quality Assurance Data Packages and NPGD Certificate of Conformance."
c.
The NPGD operating instruction 01-1000 Revision 3, " Review of QA Data Packages", was reviewed for consistency with respect to the guidelines of the Quality Assurance Manual.
d.
The QC Surveillance Data Package Log was reviewed for proper dispositioning and transmittal of Data Packages upon. final review
'and issuance of Certificate of Conformance (C0C) by QCS.
Five (5) Data Packages were retrieved from Document Cantrol to verify that the-packages were being properly transmitted upon final review.
a 21 The following Quality Control Surveillance inspection reports on e.
"in process" activities at supplier shops were reviewed for proper implementation of procedures:
(1) Bingham-Willamette Company report #7-029121 dated October 2, 1980.
Type of inspection:
L. P., hydro and baffle orientation, post test, and cleanliness.
(2) Bingham-Willamette Company report #8-029121 dated October 27, 1980.
Type of inspection:
Hydro test.
(3) Fisher Controls report #14 dated October 28, 1980. Type of inspection:
Performance test.
(4) Dresser Industries report #1.
Type of inspection:
Performance test and final inspection.
(5) Velan, report #1 dated August 11, 1980.
Type of inspection:
4 100% per procurement ordering data.
(6) Dresser Industries,-report #22 dated May 5, 1980.
ype of T
inspection:
In process f.
The following Quality Control Surveillance final inspections were reviewed:
(IT Stearns-Roger P0 #029472.
Type of inspection:
Final cleaniness and data review.
(2) Stearns-Roger PO#026419.
Type of inspection:
Final-and packaging.
(3) CCI PO #030218.
Type of ins'pection:
Testing'and data review.
(4) CCI P0 #027049.
Type of inspectica:
Testing, final, and data review.
(5) Vetro Labs PO #032825.
Type of inspection:
Final.
g.
Five (5) Document Release Notices (DRN's) were reviewed for proper. implementation of procedural requirements.
h.
Four (4) procurement packages were reviewed for proper content and evidence of proper implementation of procedures.
In these Procurement Packages was the QA generated Source Visitation-Plan (SVP), which outlines-inprocess inspections, performance evaluations, and final inspections that need to be completed before a. release
22 3.
Findings Deviations From Commitment. Unresolved Items and Followun Items None were identified.
(