ML20010H980
| ML20010H980 | |
| Person / Time | |
|---|---|
| Issue date: | 09/03/1981 |
| From: | Barnes I, Kelley W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010H977 | List: |
| References | |
| REF-QA-99900262 NUDOCS 8109290467 | |
| Download: ML20010H980 (13) | |
Text
T U. S. NUCLEAR REGULATCRY COMMISSION OFFIC" 0F INSPECTION AND ENFORCEMENT REGION IV Report No. 99900262/81-01 Program No. 51300 Company: Babcock & Wilcox Control Components International 2567 S. E. Main Street Irvine, CA 92714 2!B/
Inspector:
/
Wm. D. Kelley, Cdntractog Inspector-Mechanical Engineet Date Reactive Inspection Section Vendor Inspection Branch Approved by:
M 9/J[f/
I. Barnes, Chief Date Reactive Inspection Section Vendor Inspection Branch
, Summa ry Inspection conducted on June 22-24, 1981 (Report No. 99900262/81-01)
Areas Inspected:
Implementation of 10 CFR Part 21; 10 CFR Part 50, Appendix B; and applicable codes and standards including:
initial manage-ment meeting; quality assurance program review; design and document con-trol; manufacturing process control; and the Babcock and Wilcox Nuclear Power Generation Division 10 CFR Part 21 Report concerning the failure of the make up flow control valves to meet their design specification ficw rate. The inspection involved 22 inspector-hours on site.
Results:
In the five areas inspected, no nonconformances or unresolved items were identified in three areas. The following were identified in the remaining two areas:
Nonconformances:
Manufacturing Process Control Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraph 4.0 of Section 15 of the ASME accepted Quality Assurance Manual, QAM-100, the weld preparation on Part No. 922501043 Body Shop Order 21408-7-000, had been damaged and an NCMR had not been prepared (Notice of Noncon-formance, Item A.).
8109290467 810910 PDR GA999 EMVBW 99900262 PDR
5abcock&Wilcox 2
Contrary to Criterion V of Appendix B to 10 CFR Part 50, paragraph 3.0 of Section 12 of the ASME accepted Quality Assurance Manual QAM-100 and paragraph l
" Calibration Intervals," of BW-CCI Quality Standard 1713-01, the system did not assure recall of all measuring system equipment as evidenced by the observation June 23, 1981, of a Scherr Tumico Optical Comparator (No.1179) which had an indicated calibration due date of April 23, 1981, on the cali-bration sticker and had not been calibrated (Notice of Nonconformance, Item B.).
Item Requiring Follow up Inspection:
Flow Control Valves in the Makeup and Purification System Failure to Meet Design Specification Data Sheet Flow Rate - Babcock Wilcock Control Components International has submitted their Proposal No. CFP-81-01 to supply bypass makeup flow control valves to meet Revision 5 of the design specification data sheet requirements and assure long term system reliability.
The inspector will review the design of the supply bypass makeup flow control valves during a subsequent inspection.
i
2 DETAILS SECTION A.
Persons Contacted Babcock & Wilcox - Control Components International (BW-CCI)
W. Carter, Manager, Marketing Operations
- B. Landau, Manager of Project Engineering
- H. Miller, Vice President of Engineering V. K. Nagpal, Manager Technical Support T. Nessa, Quality Control Manager R. Tallman, Quality Assurance Engineer
- R. Topping, Director of quality Assurance
- Denotes those persons attending the exit interview.
B.
Initial Management Meeting 1.
Objectives
'The objectives of this area of the inspection were to accomplish the following:
a.
To meet with the BW-CCI management and those persons respon-sible for the administration of the ASME accepted Quality Assurance program for the purpose of establishing channels of communication.
t b.
To determine the extent of the company's involvement in the commercial nuclear business.
c.
To explain the NRC's direct inspection program including the Licensee Contractor Vendor Inspection Program (LCVIP), Vendor l
Inspection Branch (VIB) organization, and the VIB inspection methods and documentation.
d.
To describe the NRC evaluation of the ASME inspection system.
2.
Method of Accomplishment The preceding objectives were accomplished in a meeting on June 24, 1981. The following is a summary of the meeting:
a.
Attendees were:
l B. Landa's, Manager of Project Engineering H. Miller, Vice President of Engineering R. Topping, Director of Quality Assurance
3 b.
The VIB organization was described and its relationship to Region IV and the headquarters component of NRC Office of Inspection and Enforcement.
c.
The LCVIP function was described including the reasons for its establishment, its objectives, its implementation structure, and the more significant program changes, d.
The conduct of VIB inspections was described and how the inspections results are documented and reported, and what the responses to reports should include. How proprietary information is handled, the Public Document Room, and the White Book were also explained.
e.
The purpose, scope, and status of the NRC's two year program to evaluate the ASME inspection system as an acceptable independent third party were discussed, f.
The company's contribution to the nucleae industry was discussed including current and projected activities, the status of the ASME Certification of Authorization, and the third party inspection services.
3.
Results Management acknowledged the NRC presentation as being under-stood by them, and provided the inspector with the following information concerning the company's activities and products:
a.
BW-CCI holds valid ASME Certificates of Authorization Nos. N-1404 and N-1405, for Class 1, 2, and 3 valves, valve parts, and appurtenances. The certificates do not specify range of sizes, or pressure classes, and they expire on June 7, 1982.
b.
The BW-CCI has four active contracts to furnish feed regula-tor and atmospheric dump valves to the nelear industry.
c.
The Authorized Inspection Agency is Hartford Steam Boiler Inspection and Insurance Company, and the Authorized Nucleu.
Inspector provides inspection services on an itinerant basis.
C.
Quality Assurance Program Review 1.
Objectives The objecti.us of this area of the inspection were to ascertain whether the QA program has been documented in writing, and if L
4 properly implemented, will ensure that the specified quality-of completed components has been achieved in compliance with NRC rules and regulations, code and contractual requirements.
Also, ascertain whether the program provides for the following:
a.
Management's policy statement concerning QA.
b.
Delineates how the QA organization is structured, to achieve appropriate independence from scheduling and costs, the freedom and independence to identify quality problems, initiate appropriate resolutions, and verify corrective < action.
c.
Whether the duties and authority of the QA staff are clearly delineated in writing, that they have access to a level of management that can ensure effective implementation of the QA program elements, and to enforce positive and timely corrective action.
d.
Detailed written procedures are properly reviewed, approved, released, and issued to control quality activities, as appropriate.
e.
A training and indoctrination program to improve or main-tain the proficiency of personnel: (1) performing quality activities, and (2) verifying that quality activities have been correctly performed.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual to verify compliance with Appendix B of 10 CFR Part 50.
b.
Review of appropriate organization charts.
c.
Review of the documents concerning 'the authority, duties, independence, and freedom of the Quality Assurance staff.
d.
Review of the Statement of Authority.
e.
Review of the ASME accepted Quality Assurance Manual and the procedures listed in paragraphs D.2.b and E.2.b to verify that they had been reviewed and approved by authorized personnel.
f.
Review of the training and indoctrination program require-ments.
5
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3.
Findings a.
Within this area of the inspection, no nonconformances or unresolved items were identified.
b.
The evidence demonstrates that the QA program has been documented in writing and defines the duties, authority, and organizational independence, and freedom of the QA staff. Detailed written implementing documents are appropriately reviewed, approved, released, and issued by authorized personnel. The QA staff has access to a level of management to ensure effective implementation of the program and timely and positive corrective action of enforcement items. A training program has been provided for upgrading and maintaining the proficiencies of personnel involved in quality activities.
D.
Design and Document Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Procedures had been prepared and approvtf by the vendor to prescribe a system for the control of the design and document control which are consistent with NRC rules and regulations and his commitments in the ASf1E accepted Quality Assurance Program.
b.
The design and document control procedures are properly and. effectively implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following santions in the ASME accepted Quality Assurance Manual, QAM-100, Revision 5.
(1) Section 3, " Design Control," and (2) Section 6, " Document Control,"
to verify the vendor had established procedures which pre-scribe a system for control of design input.
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6 b.
Review of the following procedures:
(1) 1707-02, "0wners Certified Design Specification Control (Nuclear),"
(2) 1704-01, " Design Control," and (3) 1707-07, " Change Control Nuclear Contracts,"
to verify that they had been prepared by the designated authority, approved by management, and reviewed by QA.
c.
Interviews with personnel to verify that they are know-ledgeable in the procedures applicable to design.
3.
Findings a.
Within this area of the inspection, no nonconformances or unresolved items were identified.
b.
The inspector verified that:
(1) procedures had been prepared and approved by the vendor which prescribe a system for the control of the design and document control which are consistent with NRC rules, and regulations, and his comitments in the ASME accepted Quality Assurance Program; and (2) the design and document control procedures are properly and effectively implemented.
E.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to ve.ify that the vendor's manufacturing processes were:
a.
Performed under a controlled system which meets the NRC rules and regulations and the vendor's commitments in his ASME accepted Quality Assurance Program, and b.
Effective in assuring product quality.
2.
Method of Accomplishment The preceding objectives were accomplished by:
7 a.
Review of the following sections of the ASME accepted Quality Assurance Manual, QAM 100, Revision 5.
(1) Section 8, " Identification and Control of Materials and Services;"
(2) Section 9, " Control of Manufacturing Processes;" and (3) Section 15, " Nonconforming Materials or Items;"
to verify that procedures had been established which pre-scribes a control system of the manufacturing processes.
b.
Review of the following procedures:
(1) 1706-01, " Traveler Issue-Nuclear;"
(2) 1706-02, " Traveler Chanaes and Processing of Engineer-ingChangeOrder(EC0's)-Nuclear;"
(3) 1706-03, " Traveler Splits;"
(4) 1716-01, " Nonconforming Material Report Preparation;"
to verify that the control system requires shop travelers to be prepared which identifies the document numbers and revisions to which the process must conform. Also, to verify that all processes and tests are to be performed by qualified personnel using qualified procedures.
c.
Review of the shop travelers, or process control checklists, to verify that spaces are provided for reporting the results of specific operations, or reference to other documents where the results are maintained. Also, that it includes space for the sign off by t' 2 vendor, indicating the date on which the operation or test was perfonned, and space for sign off and date by the authorized nuclear inspector to document his acceptance of activities that he has selected as mandatory hold points.
d.
Review of the shop travelers for the following parts:
(1)
Part No. 321501643, Bonnet, Shop Order 23466-1-047; (2) Part No. 320601546XX, Plug, Shop Order 23469-1-040:
(3)
Part No. 922501043, Body, Shop Order 21408-7-000; and (4)
Part No. 320601125, Plug, Shop Order 18789-9-019;
8 to verify their compliance with the above referenced pro-cadures and the overall QA program documentation require-ments, including the establisiiment of mandatory hold points by the authorized nuclear inspector.
e.
Interviews with personnel to verify they are knowledgeable in the procedures applicable to manufacturing process control.
3.
Findings Within this area of the inspection two nonconfonnances were identified (See Notice of Nonconformance, Enclosure, Item A. and B.).
No unresolved items were identified.
F.
Flow Control Valves in the Makeup and Purification System Failed to Meet Design Specification Data Sheet Flow Rate
===1.
Background===
Babcock & Wilcox - Nuclear Power Generation Diviston (BW-NPGD),
notified the Nuclear Regulatory Commission IRKC), Office of Inspection and Enforcement (IE), by letter nated January 9, 1981, of the failure of the 2k,"> 2k" 1500 ptm A, globe valves 2
(supplied to Washington Public Power Supply oystem (WPPSS),
Nuclear Projects Units 1 and 4 and Portland & aeral Electric (PGE), Pebble Springs Nuclear Plant, for use as makeup flow con-trol valves in the makeup and purification systems) te meet the two gallon per minutc flow requirement in the closed position as specified in the BW-NPGD Design Specification 08-1148000002-0',.
BW-NPGD notified WPPSS and PGE, who had received these valves, of the deficiency and initiated a program to determine the best method of providing the required flow when the valves are in the closed position.
The two valves, for the WPPSS project are identified as Tag No.
MU-V46 and the one valve for the PGE project is also identified as Tag No. MU-V46.
2.
Objectives The objectives of this area of the inspection were to ascertain whether BW-CCI had determined the cause of the failure of the valves to meet the two gallon per minute flow rate in the closed position as specified in the BW-NPGD design specifica-
~
tion data sheet. Also, ascertain whether the failure had been processed, evaluated, and reported in a manner consistent with NRC rules and regulations and 10 CFR Part 21.
u
9 I
3.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of BW-NPGD Purchase Order 026312LF d une J, 1973, and accompanying Technical Specificatio....or the valves to determine:
(1) the applicable codes and standards;-
l (2) the design operating conditions, pressure, tempera-ture and function; and (2) whether Appendix B of 10 CFR Part 50 and/or 10 CFR Part 21 had been imposed.
b.
Review of BW-CCI Quality Assurance Manual, applicable at the time of design and manufacture of the valves, to verify that BW-CCI had a quality assurance program that met the requirements of NRC rules and regulations, Appendix B of 10 CFR Part 50, and the customer's purchase documents and/or design specifications.
c.
Review of the following BW-CCI drawings:
(1) Drawing No. 920804010, Revision 0, " Body Assembly 2h" x 2h" 1500 lb. Globe 1.50" Dia. Plug;" and (2) Drawing No. 920706018, Revision 0, " Drag Valve 2h" x 2b" 1500 ANSI, Globe Makeup Flow Control Valve;"
to verify the design of the valves supplied to WPPSS and PGE.
d.
Review of the BW-NPGD Change Orders to the original Purchase Order 026312LF, to determine when the two gallon per minute flow requirement in the closed position for the make up flow control valves was established.
e.
Review of BW-CCI Supplier CVAR 16940-1 dated September 19, 1980, to verify they had notified BW-NPGD of their failure to meet the design specification data sheet flow require-ment.
f.
Review of BW-CCI Supplier CVAR 16940-1, Revision 1, dated June 23, 1981, to verify BW-NPGD had approved and accepted the make up flow control valve "as is," and that a bypass valve would be installed to assure long term system reliability.
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Review of BW-CCI letter of May 29, 1981, transmitting their Proposal No. CFP-81-01 in response to BW-NPGD Bid Request No. 81-23 to verify that Bypass Makeup Flow Control Valves were being procured to meet the modified system require-ments.
h.
Review cf the BW-CCI Hydrostatic, Seat Leakage and Performance Test Report for Valve Tag No. MU-t'46 to verify that the seat leakage test was conducted and determine the tyne of performance test conducted. Also, verify that tests were witnessed by the BW-NPGD inspector, i.
Review the " Form NPV-1 Manufacturers' Data Report for Nuclear Pump or Valves" to verify the valves were certified as meeting Class 2 requirements.
4.
Findings a.
Within this area of the inspection no nonconformances or unresolved items were identified.
b.
Item Requiring Follow up Inspection: BW-CCI has submitted their Proposal No. CFP-81-01 to supply Bypass Makeup Flow Control Valves to meet the two gallon per minute flow in the closed position specified in Revision 5 of the design specificaticn data sheet and assure long term system reliabili ty. The inspector will review the valve design during a subsequent inspection.
c.
Comments :
(1)
BW-NPGD requested BW-CCI to perform a prolonged life expectarcy study of their 2h" x 2h" 1500 pound flow control valve installed in the Sacramento Municipal Utility District (SMUD) Rancho Seco Nuclear Generating Station, Unit 1, in 1979. BW-CCI realized they had.
furnished BW-NPGD similar valves for installatior in WPPSS Nuclear Projects Units 1 and 4 and PGE Pebble Springs Nuclear Fiant, and initiated a review of their design, the customer design specifications, and the customer purchase documents of ther.a valves.
In the course of the review, it was discovered that the BW-NPGD original design specification did not specify a two gallon per minute flow rate for the valves in the closed position; however, a note had been added to Revision 5 (dated February 20,1976), of the data sheet.for the makeup flow control valves ordered for the WPPSS and PGE plants. BW-CCI notified BW-NPGD in a telephone conver-sation in November 1979 of the failure of the makeup L
11 flow control valves to meet the Revision 5 design speci-fication data sheet flow requirement in the closed position. BW-CCI initiated Supplier Contract Variation Approval Request (CVAR) No. 16940-1 requesting the valves be accepted "as is" because, even though the noncompliance with the design specification data sheet could be corrected by changing or modifying the valve trim, the long term system reliability required a system modification. BW-NPGD did not accept the CVAR as written and it was revised by BW-CCI and re-submitted on January 23, 1981, and accepted by BW-NPGD on February 25, 1981.
BW-NPGD issued Change Order.io. 12 to their purchase order on March 3,1981, incorporating the Supplier CVAR into the purchase order and imposed the requirements.of 10 CFR Part 21.
(2) The original purchase order specified that the 2b" Makeup Flow Control Valves were to meet ASME Section III Class 2, requirements, and be designed and manufactured under the
" Quality Assurance Program for Nuclear Safety Class 2 Equipment," Specification No. 09-1213000001-00, dated February 9, 1973. BW-NPGD Design Specification 08-1148000002 specifies the 1971 Edition of the ASf;E Code with the Winter 1972 addendum as the applicable code.
(3) The BW-CCI original makeup flow control valve design was based on the requirements of paragraph 6.2 of Design Specification 08-1148000002-00 dated January 12, 1973, which states in part, "All valves shall be given seat tests... valves shall not show a leakage greater than 1/10 of 1% of its maximum capacity...." The Data Sheet for the make up flow control valves gave the flow and syst( 1 conditions, but the lowest flow specified was six gallon per minute.
BW-NPGD issued Change Order No. 6 to the purchase order on december 12, 1975, and incorporated Revision 4 (effective date June 23, 1975,) of the design specification. This revision included a flow chart attached to the make up flow control valve data sheet with the statement, "The cross hatched area is the desired operational capacity of the valve." The flow requirements on the data sheet had been revised and the minimum flow requirement was 16 gallons per minute.
(4) BW-NPGD issued Change Order No. 9 to the purchase order on April 18, 1977, and incorporai.ed Revision 7, (effective date December 17,1976), of the design specification.
Revision 5, (effective date February 20,1976),and
12 Revision 6, (effective date March i.2,1976), were not transmitted to BW-CCI until Revision 7 was made part of the contract with Change Order No. 9.
Revision 5 added a note to the Data Sheet which stated, " Valve minimum flow with valve fully closed and a P=820 psi is 2.0 gpm."
However, neither the flow chart was revised to include the new requirement, nor was the flow rates of the valve changed on the data sheet.
5.
Evaluation of Reportability BW-CCI evaluated and reported the failure of the make up flow control valves to meet the two gallon per minute flow rate in the closed position to their customer.
In addition, BW-CCI reviewed past orders to verify that all revisions to the purchase documents had been evaluated, and the personnel that reviewed purchase order change orders were instructed the revised purchased documents must be compared with the active purchase documents to assure that all revisions were evaluated.
G.
Exit Interview At the conclusion of the inspection on June 24, 1981, the inspector met with the company's managemer.t, identified in paragraph A, for the purpose of informing them tne results of the inspection.
During this meeting each identified nonconformance was discussed and the evidence which supported the findings were identified.
The company's management acknowledged the findings and supporting evidence as being understood, but had no addition.1 comments.
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