ML20005G140
| ML20005G140 | |
| Person / Time | |
|---|---|
| Issue date: | 01/12/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20005G134 | List: |
| References | |
| REF-QA-99900030 EA-89-244, NUDOCS 9001180184 | |
| Download: ML20005G140 (3) | |
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BW/IP International, Incorporated m
Long Beach,. California v <
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APPENDIX B NOTICE OF NONCONFORMANCE L
During an inspection conducted at the Vernon, California facility on 4
September 11-14, 1989, the implementation of the BW/IP quality assurance (QA) program was reviewed. _The results of the inspection revealed that certain
. activities were not conducted in accordance with NRC requirements.
These items are set'forth below and have been classified as a nonconformance to the requirenents of 10 CFR Part 50, Appendix B, imposed on BW/IP by contract, and the-BW/IP Nuclear Program Quality Manual (NPQM), Second Edition, dated June 1, 1988.
I.-
Criterion III,." Design Control," of 10 CFR 50, Appendix B, requires, in
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part, that measures-be established for the selection and review for L
suitability of application of materials, parts, equipment, and processes I;
that are essential to the safety-related functions of the structures, systems and. components.
Contrary to the above, BW/IP failed to adequately demonstrate the suit-
. ability of BJeplacement check valve swing arms supplied to the Comanche Peak Steam Electric Station.
BW/IP's dedication consisted primarily of a material identity test, a visual, and a dimensional verification.
- However, the NRC inspectors determined that BW/IP's dedication was inadequate since e
the swing arms' primary critical characteristics, mechanical and chemical properties, could not be verified using the test instrument employed. The device used was only capable of sorting between generic alloy groups such as austenitic-and martensitic stainless steels, but could not distinguish i
between any one of the four typical martensitic specifications used by u
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In addition, the results of the visual inspection performed on the was not documented.
The check valve. swing arm, classified by BW/IP as a critical.nonpressure boundary item, is essential to the operation of the swing check valve which is used in various safety-related applications at the Comanche Peak Steam Electric Station and other nuclear facilities (89-01-02).
II. Criterion VII, " Control of Purchased Material, Equipment and Services,"
of.10 CFR Part 50, Appendix B, requires, in part,.that measures be estab-lished to assure that purchased material, equipment, and services conform to the procurement documents and include provisions for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery.
In addition, the effectiveness of the control of quality by the contractor shall be assessed at intervals consictent with the importance, complexity, and quantity of the product or services.
A.
Section 7-3, " Vendor Surveys and Audits," of the BW/IP NPQM which in part implements Criterion VII of 10 CFR Part 50, Appendix B, requires in Section 7-3.3.(6b) that suppliers of safety-related QL 1, 3, and 4 items shall be surveyed initially and audited triennially thereafter.
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BW/IP-International, Incorporated :
Long Beach, California-Contrary to the above:
1.
BW/IP failed to perform implementation audits, to ensure that the supplier was effectively implementing its approved QA program.
Ir. aadition, BW/IP failed to perform triennial a'uoits
- for 17 suppliers.of safety-related material due to their status
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~ as holders of Quality Systems Certificates issued by the Ameri-can Society of Mechanical Engineers (ASME).
Items furnished to BW/IP by these suppliers-included, but were not limited to, ifasteners, castings, valves and valve internals, piping, vessels, pecial testing' services, and filler material
'(89-01-03.
2.
BW/IP failed to adequately qualify ACME Castings, Incorporated as a supplier of safety-related QL 3 and 4 items. ACHE's quality program, based on Military Specification MIL-I-45208A,
" Inspection System Requirements," was disapproved by BWr!P on November 11, 1985.. On June 8,1987, ACME's vendor status was L
changed to that of a QL 3 and 4 supplier. This' change was D
- based solely on ACME's certification that they comply with the L
provisions of 10 CFR Part 21(89-01-04).
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3.
Forty-three suppliers, currently on the BW/IP Approved Vendor L
List (AVL) as suppliers of safety-related QL 1, 3, and 4 items, L
were not surveyed initially and have not been audited triennially (89-01-05).
5 B.
Section 7-2, "Evaluattun and Selection of Suppliers," of the BW/IP NPQM which in part implements Criterion VII of 10 CFR Part 50, Appendix B, states in paragraph = 7-2.1 that the Supervisor of Quality Audits is responsible for evaluation of the prospective supplier's quality assurance program and for conducting surveys when required. Section 7-3,
" Vendor Surveys and Audits," states in paragraph 7-3.4(1) that the E
results of each audit shall be sumarized by the lead auditor on audit reports per'BW/IP Procedure 18-1.
Section 18-1, " Quality Assurance Program Audits," of the BW/IP NPQM which in part implements Criterion XVIII of 10 CFR Part 50, Appendix B, further states in paragraph 18-1.3(1), that elements selected for audit shall be evaluated against requirements and that objective evidence shall be examined as necessary to cetermine if elements are implemented effectively.
Contrary to the above, Quality Survey / Audit Reports and Quality Audit Checklists for vendors / suppliers evaluated by BW/IP and cur-rently on the BW/IP AVL do not provide sufficient objective evidence to demonstrate that the supplier's quality program had been effectively implemented (89-01-06).
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BW/IP International, Incorporated 1.ond Beach, California III. Criterion.XVI, " Corrective Action," of 10 CFR Part 50, Appendix B, requires that measures be established to assure that conditions adverse to quality i
are promptly identified and corrected.
In the case of significant conditions-adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
g Section 16-1, "C6rrective Action," of the BW/IP NPQM which in part t
implements Criterion XVI of 10 CFR Part 50, Appendix B, states that i
Requests for. Corrective Actions (RCAs) may be issued as e result of any condition which is considered to be detrimental to quality. RCAs shall be issued-to the Department Manager for instances involving ASME code deficiencies and for violations involving by-passed hold tags.
Contrary to the above, BW/IP's corrective action program is considered -
inadequate in that RCAs are not issued for conditions considered detrimental to quality for nonpressure boundary, non-ASME Code
' safety-related items- (89-01-07)
IV.
Criterion XVII, " Quality Assurance Records," of 10 CFR Part 50,- Appendix B, requires that sufficient records shall be maintained to furnish evidence l
l-of activities affecting quality and shall include at least the following:
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operating logs and the-results of reviews, inspections, tests, audits, monitoring of work performance, and materials analysis.
Records shall also be. identifiable and retrievable.
Section 17-1.0, " Control and Maintenance of Quality Records," of the BW/IP NPQM which in part implements Criterion XVII of 10 CFR Part 50, Appendix B, l-requires in Section'17-1.4(3) that quality assurance records be retained i
as outlined in Section 17-1.4, Table 1.
Such records include code data i
reports, engineering design calculations, and drawings.
Contrary to the above:
1.
- BW/IP did not provide a system for adequate quality record retention I
and retrieval. The engineering design calculations supporting the basis of two valve product lines, used in safety-related applications, could not be produced during the inspection. The two valves identi-fied were a 3-inch, 150 lb., stainless steel, manual gate valve supplied to the CPSES, Units 1 and 2, and a 12-inch motor o gate valve supplied to Bellefonte, Units 1 and 2 (89-01-08)perated 2.
Engineering Change Notices and related calculations were not available to support the identification of cause and the specific corrective actions taken to prevent recurrence for two deficiencies related to bolt torquing specifications for valves in the BW/IP product line.
These valves are identified on BW/IP drawings 79760 and 80590 and were used in nuclear safety-related applications (89-01-09).
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