ML19351E911
| ML19351E911 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1980 |
| From: | Breaux D, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351E858 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8012190522 | |
| Download: ML19351E911 (15) | |
Text
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9 U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCE.ENT REGION IV Report No. 99900400/80-02 Program No. 51100 Company: The Babcock & Wilcox Company Nuclear Power Generation Division P. O. Box 1260 Lynchburg, Virginia 24505 Inspection Conducted: July 7-11, 1980 Inspectors:
N 3/II!80 D. F. Fox, Inspector Date Program Evaluation Section Vendor Inspection Branch M
b llIl $O s
D. G. Breaux, Inspecty :
Da'te Program Evaluation Se nion Vendor Inspection Branch Approved by:
/
C. J. H2re, Chief Date Program Evaluation Section Vendor Inspection Branch Sununary Inspection on July 7-11, 1980 (99000400/80-02)
Areas Inspected:
Implementation of Title 10 CFR 50, Appendix B, and Topical Report BAW-10096A including design interfaces, procurement document control, followup on NRC regional requests, and action on previous inspection findings.
The inspection involved fifty-four (54) inspector-hours on-site by two (2)
USNRC inspectors.
Results:
In the four (4) areas inspected, four (4) deviations from commitment were identified in two (2) of the areas.
Deviations: Followup on Previous Inspection Findings.
(1) Corrective actions i
and preventive measures were not completed as committed (See Notice of Deviation i
Item A).
CVARs (Contract Variation Approval Requests) were not categorized, reviewed, nor approved in accordance with procedures (See Notice of Deviation l
Item B).
The HDL (Historical Document List) did not indicate the correct status i
8012190 h
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of CVARs (See Notice of Deviation Item C).
Procurement Document Control - PULs (Product Upgrade List) were not prepared, approved, controlled, nor execucted in accordance with procedures.
(See Notice of Deviation Item D).
3 i
DETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contacted
- C. A. Armontrout, Leader, Audit Section R. W. Colby, Engineer, Systems Engineering
- J. L. Davis, Manager, Data Administration E. V. DeCarli, Manager, Quality Assurance R. V. DeMars, Manager, Fuel Mechanical Design C. G. Dideon, Supervisor, Fuel Design Control E. F. Dowling, Manager, Plant Protection Equipment J. E. Galford, Manager, Systems Mechanical Analysis G. F. Glei, Manager, RCS Component Engineering
- D. F. Lee, Manager, Equipment Engineering
- A. L. MacKinney, Manager, General Services J. W. Mitchen, Manager, RCS Mechanical Design P. G. Perry, Manager, QC Surveillance C. B. Reynolds, Engineer, Auxillary Equipment
- D. H. Roy, Head, Engineering Department
- Denotes those present at the exit meeting.
B.
Action on Previous Inspection Findings 1.
(0 pen) Deviation A (Report 79-0!.): A calculation did not include sources of design input, computer program names, versions and dates of runs.
The inspector reviewed the correction of the calculation and the results of the B&W QA audit of calculation files which was part of the proposed corrective and preventive measures committed in B&W letters of response dated February 26, 1980 and May 1, 1980; however, additional information i
on the proposed correction of other calculations with similar deficiencies has been requested of B&W.
i 2.
(Closed) Deviation 3 (Report 79-04):
The Historical Document List I
(HDL) did not provide the correct identification and status of a QA documentation package.
The inspector examined and found 0.5e corrective action and preventive measures as described in the letters of response dated February 26, 1980, and May 1, 1980. However, the preventive measures committed therein were not completed as scheduled.
This constitutes a deviation from commitment.
(See Notice of Deviation Item A.3.)
l 3.
(Closed) Deviation A (Report 80-01): QA records were not legible, not completely filled out, or not adequately identifiable to the item involved.
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4 The inspector examined and found acceptable the corrective and preventive measures as described in B&W letter of response dated May 19, 1980. Legi-bility of upgraded records will be verified during subsequent inspection.
4.
(Closed) Deviation B (Report 80-01):
Permanent audit files did not include checklists as required.
The inspector examined and found the corrective action and preventive measures as described in the B&W letter of response dated May 19, 1980.
However, the preventive measures committed therein were not completed as scheduled.
This constitutes a deviation from commitment.
(See Notice of Deviation Item A.I.)
5.
(Closed) Deviation C (Report 80-01): QA audit procedures did not contain all of the requirements contained in ANSI N45.2.12.
The inspector examined and found the corrective action and preventive measures as described in the B&W letter of response dated May 19, 1980.
However, the preventive measures committed therein were not completed as scheduled.
This constitutes a deviation from commitment.
(See Notice of Deviation Item A.2.)
6.
(Closed) Unresolved Item (Report 80-01):
CVARs (Contract Variation Approval Request) which sppear to authorize design changes may not receive review and approval commensurate with the original design documents.
The inspector examined cen (10) CVARs and concluded that eight (8) of the ten (10) CVARs were either not categorized, or were improperly categorized and thus not reviewed and approved in accordance with established procedures.
This unresolved item was elevated to a deviation from coemitment.
(See Notice of Deviation, Item 3.)
1.
(Closed) Followup Item (Paragraph II D.3.b of Report 79-04):
It could not be determined that all issued NPGD Comprehensive Adminis-trative Manuals were complete and current. The inspector examined the report by B&W Release Administration on their 100% audit of all procedures contained in all manuals at all manual stations and concluded that all issued manuals contained the latest revision of issued procedures, were serialized and were properly assigned to cognizant individuals.
5 C.
Quality and Reporting Requirements for Burnable Poison Rod Assemblies 1.
Background Information The Region IV Vendor Inspection Branch (ComponentsSection II) noted during a routine programmatic inspection of B&W's Fuel Manufacturing Facilities that the procurement documents for Burnable Poison Rod Assemblies (BPRA) did not identify 10 CFR 21 reporting requirements as being applicable to their fabrication and requested determination of the applicable safety and quality classification and reporting require-ments.
2.
Objectives To determine the safety classification, quality classification, and 10 CER Part 21 reporting requirements for burnable poison rods, coupling-spiders, and BPRA (Burnable Poison Rod Assemblies).
3.
Method of Accomplishemnt Interviews with engineering (Fuel Engineering Systems and Mechanical Design) and quality personnel, and review of the following documents:
a.
Equipment Specification 07-10000584-02 (Quality Classification System) to determine the B&W imposed quality and safety classi-fication of the BPRA assemblies and components.
b.
QRM (Quality Requirements Matrix) 48-1003363-08 (Sheet 1), for BPRA assemblies and QRM 48-1003363-05 for BPRA components to deter-mine the B&W imposed quality and 10 CFR Part 21 reporting require-ments for SPRA components and assemblies respectively.
c.
QRM 48-1401-05 for Fuel Asrmeblies and QRM 48-1001299-04 for Fuel Components to determine the B&V imposed quality and 10 CFR 21 reporting requirements for Fuel Assemblies and Components respec-tively.
4.
Findings I
a.
Burnable poison rods, coupling-spiders, and BPRA assemblies are classified by B&W as "Nonsafety-related" and " Quality Class 3".
10 CFR Part 21 repoeting requirements were not imposed on these items.
b.
Fuel components and assemblies are identified as " Safety-Related and " Quality Class 2."
10 CFR Part 21 reporting requirements are imposed on these items.
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6 c.
Deviations from Commitment and Unresolved Items None d.
Followup Item The basis for classifying burnable poison rods, coupling-spiders and BPRA assemblies as nonsafety-related and Quality Class 3, and for not imposing 10 CFR Part 21 reporting requirements on these components, could not be clearly determined during this inspection.
This item will be evaluated further and followed up during a future inspection.
D.
Design Interfaces 1.
Objectives The objectives of this inspection for both internal and external inter-faces were to determine that procedures have been established and implemented that:
a.
Require that design organizations identify, in writing, their interfaces for managing the flow of design information.
b.
Define and document the responsibilities of each organizational unit for the preparation, review, approval, distribution, and revision of documents involving design interfaces.
c.
Establish methods for systematically communicating needed design information, including changes thereto, across design inter-faces as work progresses.
d.
Require documentation of information transmitted between organi -
zations which identified the status of the design information or documents and incomplete items which require further evaluation, review or approval.
l e.
Require that design information transmitted orally or by other informal means is promptly documented, and the documentation I
confirmed and controlled.
f.
Identify the external organizations providing criteria, designs, specifications, and technial direction.
g.
Identify the positioas and titles of key personnel in the communi-cations channel and their responsibilities for decision making, problem resolution, providing and reviewing information.
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7 2.
Methods of Accomplishment The preceding objectives were accomplished by:
J Review of the following documents to determine if procedures a.
have been established to control designs interfaces in the areas identified in objectives a. through g. above:
1 (1) Sections 2.0, 3.0, 15.0, 17.0, and Appendix A 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 corporate programmatic commitments re-lative to the control of design interfaces.
(2) Sections 2.0, 3.0, 15.0, and 17.0 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 interfaces were correctly translated into quality assurance requirements and procedures.
(3) The following procedures contained in NPGD Administration Manual to determine that the NPGD quality assurance program requirements and procedures were correctly translated into a viable engineering program for centrol of design interfaces:
NPG-0310-38 Preparation and Maintenance of the Historical Documents Lists (HDL)
NPG-0402-01 Processing of NPGD Prepared Calculations NPG-0403-11 Signatures on Engineering Documents NPG-0405-05 Contract Variation Approval Requests (CVAR)
NPG-0405-21 Change Inquiry / Authorizations NPG-0405-22 Design Review NPG-0412-56 Processing of Design Specifications /
Requirements Documents NPG-0412-58 Processing NPGD Prepared Detail Design Documents and Plant Arrangement Drawings NPG-0412-67 Processing Technical Documents from Suppliers -
and Customers
8 NPG-0503-07 Field Change Authorization NPG-1212-12 Preparation and Processing of Procurement Documents (4) The NPGD Records Management Program Manual 1E, and the NPGD Records Retention Schedules and File References Manual IEl, to determine that the NPGD commitments relative to documenting interdisciplinary reviews of design documents were translated into a records management program and were being effectively and consistantly implemented.
The following documents were reviewed to determine if the quality assurance program for control of design interfaces was being effectively implemented on current design activities affecting quality by the B&W engineer-ing organizations:
Three (3) Applicable Documents Lists, Fourteen (14) Calculations, One (1) Change Inquiry / Authorization, Ten (10) Contract Variation Approval Requests, Six (6) Drawings, Four (4) Drawing Approval Requests, Six (6) External Documents, One (1) Field Change / Authorization Three (3) Document Comment Forms, Four (4) Quality Recuirements Matrix, and i
Fourteen '14) Specifications.
3.
Findings a.
Deviations from Commitment and Unresolved Items None b.
Followup Items l
(1) Existing procedures may not contain sufficient guidance to l
permit an individual with a safety concern to ultimately express the concern to the responsible reporting official of B&W-NPGD.
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This ites will be further evaluated during a future inspection.
(2) Existing procedures may not provide assurance that the 3
sources of design inputs to design.;Lput documents (such i
4 as Equipment Specifications), ar. occumented and traceable.
c.
Comments The area of design interfaces was identified in Report No. 80-01 a followup ites. The foregoing closes action on that ites.
E.
Exit Meeting An exit meeting was conducted with Babcock and Wilcox NPGD personnel at the conclusion of the inspection on July 11, 1980.
In addition to those 4
individuals indicated by an asterisk in the Details Sections of this j
report, the meeting was attended by:
1 W. T. Brunson, Principal Engineer, Fuel Engineering D. E. Guilbert, Vice President and General Manager A. Hall, Special Assignment, Purchasing R. E. Kosiba, Manager, Customer Service 1
A. H. Lazar, Senior Project Manager J. G. Mallin, Assistant Counsel J. H. Taylor, Manager, Licensing The inspector discussed the scope of this inspection and the details of i
the findings identified during the inspection. Management requested addi-l tional details on the findings and stated that an in-depth evaluation of the PUL (Product Upgrade List), CVAR (Contract Variation Approval Request) and HDL (Historical Document List) systems would be performed to determine the cause, extent, and significance of the non-adherences to procedual requirements. Management further stated that the evaluation l
will be completed and actions will be taken as quickly as.possible to assure that the. governing in place procedures are responsive and defini-tive and that they are being uniformly and effectively implemented by all affected personnel.
The inspector discussed the form and content of Letters of Response to NRC Inspection Reports and emphasized the importance of timeliness in their submission and in execution of the action committed therein.
I The investigator summarized the purpose and-scope of the special investi--
gation with respect to valves procured from WKM. The investigator stated that this was the initial effort concerning the investigation. %&en the investigation is completed B&W will be provided with a copy of the. final report.
i.
10 DETAILS SECTION II (Prepared by D. G. Breaux)
A.
Persons Contacted J. E. Young, QA Audit Engineer
- J. L. Davis, Manager, Data Administration C. G. Dideon, Supervisor Engineer, Fuel Design Control F. L. Snow, Component Engineer
- C. A. Armontrout, Leader, QA Audits Section D. R. Martin, Group Leader, Document Processing
- Denotes those present at the exit meeting.
B.
Action On Previous Inspection Findings 1.
(Closed) Followup Item (Paragraph II. C.3.b. of Report 80-01): The objectives of this followup were to assure that the cause of the valve body rejectable indications was identified, documented, and reported to management; and that corrective and preventive actions were pro-cessed.
To substantiate that these objectives were being addressed by B&W, a document on the subject of WKM valves titled " Evaluation of Defects Identified During Post Delivery Inspection" Revision 1 dated February 15, 1980, was reviewed. With respect to the linear indications in six (6) WPPSS Class 1 decay heat system isolation valves, B&W's statement of probable cause was that the rejectable indications in the casting were uncovered by the working of the metal, i.e. welding, grinding, machining, etc., in or near the area of the reported indications.
B&W further concluded that subsequent to the metal working no liquid pene-trant examinations were made and hence the indications were not de-tected. This conclusion was made in spite.of the fact that WK3 had no records showing that metal working was done af ter the 100% dye penetrant coverage was made.
B&W's conclusion was that the (6) Class 1 valves did not meet the code, therefore all Class 1 valves produced by WKM are suspect and must be re-examined.
Corrective action for all Class 1 valves will be in the form of re-turning, dissembling, and 100% liquid penetrant testing of the valves at the WKM facilities.
In accordance with this action, change orders to all valve purchase orders for equipment remaining to be completed for all Class 1 valves, requires a thorough visual inspection to be performed just prior to final assembly. Also, all surfaces in the finished condition shall be liquid penetrant tested just prior to final assembly.
B&W's other corrective action is to revise the standard valve procure-ment specifications to require a complete visual inspection of all y-a
.ep w
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valves just prior to final assembly. Furthermore, for Class 1 valves, all accessible internal surfaces shall be examined by liquid penetrant methods subsequent to manufacturing and prior to final assembly.
In addition, for all Class 1, 2, and 3 valves, a visual inspection of all accessible portions after hydrotesting shall be made.
Concerning the subject followup item, two cracks were discovered by WKM in valve 4CF-VIA during disassembly for Marotta retaining clip replacement.
Corrective action by B&W was that valve 4CF-VIA was technically unacceptable and had to be repaired. As an outcome of this, all Class 2 valves must be shown acceptable with respect to the Radiographic Testing technique of aaximum feasible coverage.
- Also, all Class 2 valves are to receive 100% visual inspection of all i
pressure retaining parts. All previously recorded unacceptable visual indications shall be confirmed as acceptable by liquid penetrant examination after the unacceptable indications have beer. removed.
All items of the followup appear to have been addressed by B&W.
2.
(Closed) Followup Item (Paragraph II. D.3.c.(1) of Report 80-01):
This followup was to determine why the HDL lists CVAR 87-1791-00 dated May 19, 1978, with status BA (in house for review), but no record or copy of the CVAR could be located.
In response to this ites, B&W presented -a copy of the formerly unlocated CVAR with an attached memo dated June 25,1980, From: Auxiliary Equip-ment, To: Release Administration.
This memo explains that while CVAR j
87-1791-00 was in-house being considered, the WKM QA department decided they would not allow these valves (named in the CVAR) to be shipped i
without B&W's approval of the final revision of the calculations. This condition was deemed unacceptable by B&W, therefore the CVAR was.
" disapproved" on June 24, 1980. The status of CVAR 87-1791-00 was still listed as in-house for review. With respect.to what seemed to be an inordinately long processing time for this CVAR (approximately-2 years), it was stated that a quarterly audit by the Task Engineers
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would alert them of outstanding CVAR items on his project.
In the area of status codes, new CVAR processing procedures. reflect only approved or disapproved dispositions. Since CVAR 87-1791-00 was located and was processed, this item is considered closed.
However, to further investigate this dispositioning of CVARs, an inspection of five (5) CVARs with the status of "in house for review" were examined. These CVAR's were obtained by randomly selecting B&W NPGD-Information Systems Report-0D-1011-01, Revision 0, dated June 21, 1980 (87-1019095-00,.87-0373-00, 87-1018561-00, 87-1145-00, and 87-0663-01.). Of these five (5) CVARs, listed as "in house for review" the current status of CVARs 87-1019093-00, 87-0373-00, and 87-1145-00 ware " approved" and 87-1018561.was " disapproved" indicating the actual "in nouse review" was. completed,'i.e. the HDL indicated the wrong 1 status.
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.. ~... _ _, _... _ _.
12 This discrepancy in CVAR status on the B&W NPGD - Information Systems Report is a deviation from commitment.
(See notice of Deviation Item C.).
3.
(Closed) Followup Item (Paragraph II. D. 3.c.(2) of Report 80-01):
This followup was to determine the number of projectized B&W QA manuals that exist, if they are all a version of the 19A-N-1, and if any sub-stantive differences exist between these manuals. Upon discussion with B&W QA, it was determined that two (2) project specific QA manuals as well as B&W Nuclear Power Generation Deviation QA manual 19A-N-1, exist.
The (2) two project specific manuals are:
(1) QA Manual for TVA 19A-N.1 (TVA) Bellefonte Nuclear Plant Units 1 and 2, dated April 15, 1978.
The distribution list of this Manual shows a total of thirty-two (32) manuals distributed.
(2) Vepeo Addendum to 19A-N.1 QA Manual for Virginia Electric Power Company, North Anna Power Station Units 3 and 4 and Surry Power Station Units 3 and 4.
Distribution of this manual totaled twenty-one (21).
Both of these project specific manuals were found to be extensions of the basic Power Generation Division Quality Assurance Manual 19A-N.1.
Both projectized manuals refer to 19A-N.1 for content requirements.
The additions to these project specific manuals are to identify project unique documentation or processing but equivalence to the Power Generation Division Quality Assurance Manual 19A-N.1 appears to have been maintained. This information closes this item and no deviations or unresolved items were identified.
4.
(Closed) Unresolved Item (Report 80-01):
It was not clear that B&W review and approval of CVARs, which appear to make design changes, is equivalent to the original design review and approval for CVARs.
This unresolved item was closed and elevated to a deviation.
(See Notice of Deviation Item B.)
This unresolved item was closed and one deviation was identified as described in the following paragraph C.3.a(2)(b).
C.
Procurement Document Control 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been prepared and are being implemented to assure that:
a.
The organizations involved in the execution of procurement activities have been identified and their responsibilities delineated, b.
Procurement documents include the scope of work to be performed by the supplier, the technical requirements, material and equip-
13 ment specifications, procedures and instructions, test and in-spection requirements, acceptance requirements, and identification, packaging, handling and shipping requirements.
c.
Procurement documents require that the supplier have a documented quality assurance program consistent with 10 CFR 50, Appendix B.
d.
The supplier is required to incorporate appropriate quality assurance program requirements in sub-vendor procurement documents.
e.
Procurement documents provide rights of access to the supplier's plant facilities and records, identification of manufacturing hold points, witness points and notification of the time of these events, documentation requirements, records requirements, and requirements for reporting and approving of the disposition of nonconformances.
f.
Procurement documents are reviewed by the QA organization before transmittal to the prospective suppliers and these reviews are documented.
g.
Changes to procurement documents undergo the same degree of review and controls as the original documents.
h.
Measures to control the release and distribution of procurement documents are being implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a WPPSS Nuclear Project No. 1, PSAR Volume 7, Amendment 24, Sections 17.1.4 and 17.3.4, Procurement Document Control.
b.
Quality assurance program procedures:
(1) NPG-1707-01 Revision 8 titled:
" Processing of Safety Concerns."
(2) NPG-0405-05 Revision 11 titled:
" Contract Variation Approval Request."
(3) NPG-0412-56 Revision 11 titled " Processing of Design Specification / Requirements Documents."
(4) NPG-0412-66 Revision 9 titled " Release of Product Documentation."
14 (5)
NPG-1212-13 Revision 12 titled " Nuclear Spare Parts Procurement."
(6) NPG-0412-55 Revision 10 titled " Preparation of Design Specifications / Requirements Documents."
c.
Quality Assurance Manual 19A-N.1 Revision 8, dated November 14, 1979, Section 4 titled " Procurement Document Control."
d.
Ten (10) Applicable Documents List (ADL),
e.
Ten (10) Quality Requirements Matrix, f.
Five (5) Procurement Packages, g.
Three (3) Equipment Specifications, h.
Four (4) Change Inquiry Authorization (CI/A) 1.
Thirteen (13) Contract Variation Approval Request (CVAR)
J.
Ten (10) Froduct Upgrade List (PUL) 3.
Findings a.
General (1) All Quality Assurance procedures were reviewed for content and proper B&W review. The procedures were then compared with the B&W Topical Report to confirm that these procedures reflected the topical. All procedures were consistent with respect to the topical.
(2) A review of procurement documents and packages was made to assure that quality assurance procedures were being properly implemented. This review identified the follow-tag concerns:
(a) PULs are to be used to indicate known deficiences or known changes in a document or drawing at the time the document or drawing is released.
They are also to be used to identify those higher tier documents - (identify-ing input requirements) unavailable at the time of release of the documents. Based on this review, it was concluded that PULs are not prepared, approved, distributed, controlled, upgraded, nor executed as required by procedures.
In addition, affected design documents were not revised or up graded to reflect PUL evaluation and disposition as required by procedures.
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s 15 (b) Review of CVARs identified that:
items were procured with deviations (variations) from specification require-ments; documents were not identified as Category 1 CVARs, and documents were not reviewed and approved by the Integrator (Systems Engineer) as required by procedures.
Integrator review is important in the event that system characteristics may be affected by the component technical requirements resulting from of the CVAR.
(c) All other procurement document control procedures examined appear to be properly and effectively imple-mented by B&W.
b.
Deviations Two (2) deviations from commitments were identified in this area of the inspection (See Notice of Deviation, I+. ems B. and D.).
c.
Unresolved Items None identified.
d.
Followup Item One (1) followup item was identified in this area of inspection.
It could not be determined with the documentation that all Product Upgrade Lists (PUL's) had been properly dispositioned prior to initiation of procurement activities.
In addition, the ADL (a document that lists the status of PULs against all procurement documents) provides no evidence that PUIs have ever been written against procurement documents.
It is not clear how the status of PULs is updated and disposi-tioned on the ADL document upon receipt of a PUL by the document processing group (Release Administration).