ML20005A220
| ML20005A220 | |
| Person / Time | |
|---|---|
| Issue date: | 03/24/1981 |
| From: | Chamberlain D, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20005A208 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8106300056 | |
| Download: ML20005A220 (14) | |
Text
imC U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION ANO ENFORCEMh '
REGION !V Report No. 99900400/81-01 Company:
The Babcock and Wilcox Company 7
Nuclear Power Generation Division P. O. Box 1260 Lynchburg, Virginia 24505 Inspection Conducted:
February 24-26, 1981 Inspectors:
I
- 0. F. Fox, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch Y
- 0. D. Chamberlain, Contrbetor Inspector Date Reactor Systems Section Vendor Inspection Branch b
S Approved by:
s C. Q J1e, Chief Date Reactor Systems Section Vendor Inspection Branch Summary Inspection on February 24-26, 1981 (99900400/81-01)
Areas Insoected:
Implementation of Title 10 CFR Part 50, Appendix B, and Topical Report BAW-10096A including design process management, technical personnal background verification, training, and action on previous inspection findings.
The inspection involved 50 inspector-hours on-site by two USNRC inspectors.
Results:
In the four areas inspected, three nonconformances and one unresolved item were identified in three of the areas.
Nonconformances:
Design Process Management - A B&W NPGD Certificate of Conformance and a Quality Data Package were revised without the required signatory requirements.
(See Notice of Nonconformance, Item A).
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Verification of Employee Education and Experience - Records, which document that the education and experience of new employees were verified, were not collected nor maintained in accordance with procedures.
(See Notice of Noncon-formance, Item B).
Training - Records, which document the required indoctrination and training of new employees, were not maintained in accordance with procedures.
T (See Notice of Nonconformance, Item C).
Unresolved Item:
Desiqn Process Management - It could not be determined if the quality assurance program requirements imposed by B&W on suppliers of spare ar.d replacement parts meet current NRC requirements.
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DETAILS SECTION I (Prepared by O. F. Fox)
A.
Persons Contacted D. L. Allison, Manager, Technical Support
- C. A. Armountrout, Manager, Audit Section
- E. V. DeCarli, Manager, Quality Assurance
- R. H. Ihde, Manager, Nuclear Parts Center A. H. Kirkpartick, Senior Contract Administrator C. E. Mahaney, Generic Pr )fect Manager
- Denotes those present at the exit interview.
1.
(Closed) Followup Item (Report 80-02,Section I.C.3.d).
The basis could not be determined for not classifying burnable poison rods, coupling spiders, and burnable poison rod assemblies as safety related, nor for not imposing 10 CFR Part 21 requirements.
The inspector reviewed Section 3.2 (Classification of Structures, Components and Systems) of the NRC approved PSAR for the Washington Public Power Supply System Nuclear Project No. 1, and determined that neither the burnable poison rods, coupling spiders, nor the burnable poison rod assemblies were "Q" listed or otherwise identified as safety related items.
Equipment Specification 07-10000584-02 (Quality Classification System) and QRMs 48-1003363-05 and 49-1003363-08, which define the safety classification and quality classification of thece items, reflect the PSAR commitments, i.e., burnable poison rod assemblies are classified as "Nonsafety - related" and " Quality Class 3."
10 CFR Part 21 reporting requirements are not applicable to nonsafety related items.
2.
(Closed) Followup Item (Report 80-02,Section I.O.3.b).
Existing procedures may not contain sufficient guidance to permit an individual with a safety concern to ultimately express the concern to the responsible reporting official.
The inspector reviewed revision 9 of the B&W procedure for processing of safety concerns No. NPG-1707-01 dated October 1, 1980.
The inspector determined that an individual with a safety concern initiates a pre-liminary Report of a Safety Concern.
The report is reviewed for accuracy and completeness, and signed by the individual's manager.
All signed reports are ultimately transmitted to the head of the B&W Nuclear Power Generation Division for determination of reportability under 10 CFR Part 21 after documented review / evaluation by the NPGD engineering, quality assurance, and licensing functions.
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4 Furthermore, the procedure states that if an individual is unable to obtain his manager's signature on the preliminary Report of a Safety Concern, "the individual may escalate the cor. ern through the managerial chain" to effect evaluation of the concern.
3.
(Closed) Followup Item (Report 80-02,Section I.D.3.b).
Exist'ing procedures may not provide sufficient assurance that the ssacces of design input (such as system requirements specifications) are documented and traceable to design output documents (such as equipment specifications).
The inspector reviewed the recently revised B&W procedure No. NPG-0310-38 for the " Preparation and Maintenance of the Historical Document List (HDL)" and No. NPG-0412-55 for the " Preparation of Design Specification /
Requirements Documents" and determined that: (a) procedure NPG-0412-55 identifies 30 areas to be considered and incorporated as pplicable into system requirement specifications, equipment specifications, and other design documents.
The areas to be considered include, but are not limited to the basic functions, performance requirements, applicable codes and standards, and other design inputs to the design; and (b) procedure NFG-0310-38 states that the HDL is a document listing which provides the identification, status and relationship of B&W technical documentation for a particular NPG0 product.
The contract and task-group sequence (or part) number, entered into the HOL along with the type, number, title, and status of the document, identify the documents
,to their ultimate application.
4.
(Closed) Violation (Report 80-03).
B&W failed to report to NRC, under the provisions of 10 CFR Part 21, that an identified design defect, which could create a substantial safety hazard, existed in certain WKM vr.lves that were supplied to the Washington Public Power Supply System's WNP-1/4 nuclear power plants.
Further, B&W failed to report the number and location of all such valves that were procured for the Portland General Electric Company's Pebble Springs nuclear plant.
B&W, in their letter to Region IV, dated October 10, 1980, stated that B&W did not believe that they violated the reporting provisions of 10 CFR Part 21. Nevertheless, B&W did take measures to assure that safety concerns may be identified without constraint, timely processed, evaluated and documented, and that those safety concerns determined to constitute substantial safety hazards are reported to NRC and all affected customers in a timely manner.
The inspector verified the corrective actions, generic considerations and preventive measures described in the B&W letters to th e MC dated September 24, 1980, September 26, 1580, October 10, 1980, and j
October 31, 1980.
Specifically:
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5 a.
B&W has corrected the design defect in all affected valves and has verified and documented this corrective action.
b.
B&W re-evaluated all safety concerns processed since January 1, 1978, to assure that all such concerns were properly processed and appropriata1y reported to NRC.
c.
B&W revised procedure No. NPG-1707-01 (Revision 9, dated
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October 1, 1980), entitled " Processing of Safety Concerns,"
to incorporate the IE Headquarters recommendations (letter to B&W dated July 9, 1980) and Region IV comments (NRC inspection reports 80-02 and 80-03).
5.
(Closed) Follow up Item (Report 80-03,Section I.B.3.e).
The inspector could not determine if the potential for overpressurization of certain WKM valves in the valve open position was evaluated for safety signi-ficance.
The inspector reviewed B&W and supplier documents which indicated the B&W reevaluation of this concern and that appropriate corrective was taken for all affected valves.
6.
(Closed) Followup Item (Report 80-03,Section I.B.3.e).
The inspector could not determine if B&W prepared and maintained sufficient records relating to the evaluation and testing of certain WKM valves to meet the record retention requirements of 10 CFR Part 21.
The inspector reviewed B&W and supplier documents which indicated that B&W decided to physically modify the affected valves rather than commence an extensive analysis program to determine if the alleged design defect truly constituted a substantial safety hazard.
7.
(Closed) leviation (Report 80-04, Deviation A).
Design documents were not revit:wed and approved in accordance with approved procedures.
The inspector verified the corrective action and preventive measures described in B&W letter of response dated January 13, 1981.
Specifically:
a.
The design documents identified in inspection report 80-04 were reviewed by B&W to determine that the actual reviewers and approvers of the documents were at least as qualified to perform the required reviews and approvals as the designated individuals.
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b.
A B&W internal QA audit revealed no additional non-adherences to the intent of the review and approval requirements for design documents.
c.
The Autnorized Administrative Procedures Deviation Lettet was revised to clarify the preparation, review, and approved require-ments for design documents during the interval when the governing procedures were being revised to reflect the current NPGD engineering organizations and their functions.
d.
All 2) elevant design control and procurement procedures were revised as committed.
8.
(Closed) Deviation (Report 80-04, Deviation B).
The QA Manual was not revised to reflect changes in organization, document effectivity, and design control that were affected by B&W during the past year.
The inspector verified the corrective action and preventive measure;s described in B&W letter of response dated January 13, 1981.
Specifically, the 19A-N.1 Quality Assurance Mar. cal was revised to reflect the organization, design control measures, and document effectivities currently in place within NPGD.
The QA Manual was in final typed draft stage with all reviewers' comments resolved.
Review by the Authorized Inspection Agency is scheduled for completion by March 11, 1981, and issue of the approved QA Manual by March 16, 1981.
C.
Design Process Management 1.
Objectives The objectives of this area of inspection were to examine the establishment and implementation of quality related procedures for the design process to verify that:
The design process system is defined, implemented, and enforced a.
in accordance with approved procedures, instructions, or other documentation for all groups performing safety related design activities.
b.
Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures.
Appropriate quality standards for items important to safety c.
are identified, cocumented, and their selection reviewed and approved.
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Final design can be related to the design input with this trace-ability documented, including the steps performed from design input to final design.
Design activities are documented in sufficient detail to, permit e.
design verification and auditing.
f.
The methods are prescribed for preparing design analyses, drawings, specifications, and other design documents so that they are planned, controlled, and correctly performed.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to determine if procedures have been prepared, approved, and issued to prescribe a controlled system for the management of the design process that is consistent with commitments to NRC and objectives a. through f. above.
(1) Sections 2, 3, 5 and 6 of the NRC cecepted B&W Topical Report BAW-10096A, Revision 3 to determine the B&W corporate commitments relative to management of the design process.
(2) Sections 2, 3, 5 and 6 of the B&W 19A-N.1 QA Manual and the Spare Parts Addendum to the QA Manual to determine if the B&W corporate commitments relative to management of the design process were correctly transmitted into quality assurance policies and procedures that provide coatrol over activities affecting the quality of the original design, and spare or replacement parts, that are within the B&W scope of supply.
(3) Applicabla design control procedures that are contained in the NPGD Administrative Manual to verify that procedures have been established to implement the commit',ed quality assurance program and to prescribe design activities for the original design, and spare or replacement parts, that are within the B&W scope of supply.
(4) Sections 3.2, 5.3, and 5.5 of the PSAR for the Washington Public Power Supply System Handford No. 2 Nuclear Power Plant, and Section 4.1 of the FSAR for the Duke Power Company OCCNEE Nuclear Station, Units 1, 2, and 3, to determine the safety classification, quality assurance requirements and design inputs for the thermal-hydraulic system, reactor coolant pumps, the control rod drive mechanism housing and associated bolting, and selected ASME Class 1 nuts and bolts.
8 b.
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'd records ano documents of the original design and spare an, r,lacement part orders were examined for the following iten.. to determine -if sources of design input, such as PSAR/FSAR commitments, regulatory / quality requirements, and others, were correctly and traceably translated into verified final design documents and the correspondine ultimately procured items.
(1) Control rod drive mechanisms, segment rings, bolt assemblies and bolts.
(2) Heavy hex nuts (pressure retaining closures).
(3) In-core flux detectors and thermocouples.
(4) Pressurizer heater bundle stuas.
(5) Reactor coolant pumps and miscellaneous spare parts.
(6) Reactor vessel intnnal vent valves, jack screws, and locking devices (including modifications thereto).
c.
The following documents were reviewed to determine if the quality.
- assurance program for the management of the design process was being effectively implemented by the current B&W activities affecting the quality of the original design, and spare or replacement parts, that are within the B&W scope of supply.
(1) Fourteen Applicable Document Lists, (2) Fourteen Certificates of Conformance (B&W),
(3) One Code Applicability Lists, (4) Twenty-one Contract Variation Approval Requests, (5) Nine Contracts (to determine B&W scope of supply);
(6) Eleven drawings (B&W original design, B&W spare and replacement parts, and supplier),
(7) Three Document Record Check List and Comment Forms, (8) Six Inspection Reports, (9) Thirty-nir e Procurement Authorizations, (10) Seventy P'.' chase Orders and Change Notices thereto (B&W and subtier suppliers),
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'(11) Seventeen Quality Data Packages and Transmittal Forms, (12).51even quality requirements matrices, (13) Nine Requests For Quotation,
(14) Thirty-seven specifications (original equipment and scare and/or replacement parts), and (15) Fifty-tb vendor sub 'tted documents (such as CMTR's, COC's, NOT reports, procedures, specifications, etc).
3.
Findings a.
Nonconformances One (1) nonconformance was identified in this area of the inspection.
(See Notice of Nonconformance, item A).
The B&W NPG0 Quality Assurance Manager stated that the original NSSS customer number on the official QA record copies of the Certificate of Conformance and the Quality Data Package for the control rod drive mechanism hold down bolt assemblies was improperly changed (i.e., crossed out and a different NSSS customer number handwritten in its place without the change being dated and initialed by all concered individuals) by an unidentified individual after the QA Manager had signed the documents but before the altered documents were microfilmed and entered into the QA records.
The QA Manager further stated that an in-depth examination of the requirements of the two custnmers, and the QA records associated with the items that was concuted during the NRC inspection, indicated that the items would meet the requirements of both customers.
Discussions with the Nuclear Parts Center (NPC) and Quality Assurance management indicated that the most probable reason that the QA records were changed was that the items were needed by the second NSSS customer on a higher priority basis than the first NSSS customer.
Review of the NPC working files revealed several other instances where the NSSS customer and/or the supplier numbers had been changed on the working copies of the Certificate of Conformance, Quality Data Package, Quality Requirements Matrix and Applicable Document List.
These changed numbers appear to indicate that transfers of items between different NSSS customers and/or different suppliers were impnding, or had already been executed, apparently without any formal documentation / traceability being established.
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10 While there is nothing inherently wrong with the proper, authorized, reviewed, and documented transfar of items by NPC, the concern here is that an unauthorized individual by changing the NSSS cu:tomer numbers on the B&W Certificates of Conformance and/or QA Data Packages that were previously properly reviewed and signed by the QA Manager as meeting all of the requirements of the original NSSS customer, could improperly certify that the items meet all of the requirements imposed by the second customer when in fact, they may or may not, o.
Unresolved Item The inspector could not determine if the quality assurance program requirements imposed by B&W on suppliers of spare or replacement safety related parts meet current NRC requirements.
This item will be referred to NRC Headquarters for guidance.
O.
Exit Interview An exit meeting was conducted with Babcock and Wilcox NPGD personnel on February 26, 1981.
In addition to those individucls indicated by an asterisk in the Details Sections of this report, those in attendance were:
D. E.-Guilbert, Vice President, NPG0 R. E. Kosiba, Manager, Customer Service D. H. Roy, Manager, Engineering E. A. Womack, Manager, Reactor and Fuel Management l
The inspector. discussed the scope of this 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 controlling employment practices, training, and quality assurance data packages would be performed to determine the cause, extent, and signifi-cance of the apparent nonadherance to procedural requirements.
Management further stated that the evaluation will be completed and action will be taken to assure that the governing in place procedures are definitive and that they are being uniformly and effectively implemented by all affected personnel.
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1 11 DETAILS SECTION II (Prepared by D. D. Chamberlain)
A.
Persons Contacted
- C. A. Armontrout, Manager Quality /,ssurance Audits "R. L. Bruce, Manager Employee and Public Relations G. H. Bunch, Employment Manager
- E. V. DeCarli, Manager Quality Assurance
- J. C. Deddens, Manager Business Administration and Integration Depat' ment E. G. Frassee, Manager of Salary Administration J. Yates, Manager of Training
- 0enotes those present at exit interview.
B.
Technical Personnel Background Verification 1.
Objectives To verify that measures have been established and are being effec-tively implemented that assure:
a.
The education and work experience information contained in employee's job applications are being verified by the employing organization.
b.
Therv is objective, documented evidence / records that attest to the employee's education and experience.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Personnel records of 12 employees.
b.
Employment Procedure 1406-A2.
Nuclear Power Generation Division (NPGO) procedure NPG-1406-72G, c.
Requisition and Employment of Salaried Personnel.
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NPG0 Records Retention Schedules and Files References Manual 1El.
e.
Sample of the card that is presently being used to request employment information from previous employers.
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Findings In this area of the inspection, one nonconformance was identified (See Notice of Nonconformance Enclosure, Item B).
7 The employment procedures presently in effect at Babcock and Wilcox (B&W) do not address certain key areas for personnel performing safety related work as follows:
(1) The minimum documenta-tion that is required to verify past education and experience; (2) the action that would be taken when certain education and/or experience cannot be verified; and (3) the action that would be taken if falsified qualification records are identified.
The Employee and Public Relations Manager committed to the inspector to review and revise procedures by May 1, 1981, to provide for verification of education and experience of new employees and newly assigned employees performing safety related activities.
No unresolved items or follow up items were identified.
C.
Training 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented that provide for:
a.
Formal indoctrination and training or retraining programs for new employees and reassigned employees.
b.
Training of inspection, examination and testing personnel that provide for:
(1) Indoctrination with the technical objectives of the project, the codes and standards to be used, and the quality assurance elements that are to be employed.
(2) On the job participation through actual performance of processes, tests, examinations and inspections.
(3) Testing the capability and proficiency of personnel who perform nondestructiva examinations.
(4) Retraining and recertification if evaluation of performance shows individual capabilities are not in accordance with I
specified qualifications.
l (5) Records of training received by each person including i
applicable certification of qualification and results of tests.
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Training of audit personnel, including technical specialists, that provide for:
(1) Orientation with applicable standards and procedures.
(2) General training in audit performance including funda-mentals, objectives, characteristics, organization, performance and results.
(3) Specialized training in methods of examining, questioning, evaluating, documenting specific audit items, and methods of closing out audit fi.qdings.
(4) On the job training, guidance, and counseling under direct supervision of an experienced, qualified auditor to include planning and performing audits; reporting and followup action; and review and study of codes, standards, procedures, instructions, and other documents related to QA and QA program auditing.
d.
Training programs for other personnel performing quality related activities that include:
(1) A description of quality assurance material to be presented and method of presentation.
(2)
Schedules for conducting the training sessions.
(3) Identification of individuals by job description or titles-or groups required to attend sessions.
Documentation of attendance and retention of other applicable e.
records for all formalized training accomplished.
2.
Method of Accomplishment The preceding objectives were accomplished by an examinatica of:
a.
NPGD Quality Assurance Manual, 19A-N.l.
b.
Quality Standard, NPG-1702-22, Training of NPGD Employees.
c.
Policy - Training and Education, NPG-1405-04G.
d.
Preparation, Review and Approval and Issuance of Administrative Policies and Procedures, NPG-1303-07.
e.
NPGD Administrative Manual Release No. 183.
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Training and Development Needs document.
g.
Computer printout that listed training received by individual personnel.
h.
Sample memo for a Delinquent Personnel Training Report Form.
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Training records of eight employees were examined in detail and
'the training records of ten employees were scanned.
3.
Findings a.
Nonconformances In this area of the inspection, one nonconformance was identified (See Notice of Nonconformance Enclosure, Item C).
b.
Unresolved Items and Follow Uo Items None were identified.
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