ML20023B965
| ML20023B965 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20023B954 | List: |
| References | |
| REF-QA-99900283 NUDOCS 8305090406 | |
| Download: ML20023B965 (3) | |
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APPENDIX B~
BIW Cable Systems, Inc.
Docket No. 99900283/83-01 j
NOTICE'0F NONCONFORMANCE Based on the results of an NRC inspection' conducted on February 28-March 4, 1983, it appears that certain of your activities were not conducted in accordance with NRC requirements"as indicated below:
A.
Criterion V of Appendix B to 10 CFR Part 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or
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drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Nonconformances with these requirements are as follows:
1.
Paragraph 4.1 of the BIW Quality Control Manual (QCM) states, in part, "All nomenclature and requirements (codes, standards, quality control plans, etc.) are included in the purchase order documentation and reviewed by the Quality Control manager or his delegate, purchasing department and engineering department where applicable, prior to order placement."
Contrary to the above, purchase order Nos. 2-2865, 1-3876, 830205773, and 820105013 which procured safety-related testing i-services did not contain evidence that they had been reviewed by the quality control department.
4 2.
Paragraphs 4.2 and 18.5 of the BIW QCM state, in part, " Vendor and subcontractors facilities will be surveyed by the Quality Control l
Department when required to do so by customers or when deemed necessary by vendor performance."
Contrary to the above, BIW procured safety-related testing services (for projects which customers required to be accomplished under the requirements of Appendix B to 10 CFR Part 50) from Associated Testing Laboratories and Isomedix, Inc., without having documented evidence that vendor had been audited by BIW.
3.
Paragraph 18.4 of the BIW QCM requires that followup internal audits will be accomplished within 10 working days of the original audit.
Contrary to the above, the followup audit, conducted as a result of deficiencies outlined in the internal audit report of June 23, 1982 (for the Boston plant), was not accomplished until September 23, 1982.
i 8305090406 830420 PDR GA999 EMVBIWCS 99900283 PDR
- 4.
Paragraph 1.1 of the BIW Quality Control Procedure No. 1, " Collection, Control, Storage and Maintenance of QA Records for Nuclear Power Plants,"
dated February 16, 1979, states:
"This procedure provides the minimum requirements for the collection, storage and maintenance of Quality Assurance records associated with the design and manufacture of cables for nuclear power plants." Paragraph 2.4 of the same procedure states, in part, "All records will be filed in steel, fire proof cabinets in assigned areas to preclude deterioration."
Contrary to the above, some records for completed loss-of-coolar.t accident (LOCA) tests were stored at the BIW Plymouth plant in desk drawers.
5.
Paragraph 1_6.2 of the BIW QCM-states, in part, " Corrective action, the prevention of recurrence of nonconformities is obtained, to the I
extent necessary,...." Paragraph 16.3 of the BIW QCM also states, in part, " Corrective action is initiated by the plant superintendents to prevent recurrence of the defects."
Contrary to the above, the corrective action taken to close out deficiencies outlined in the internal audit report of December 20, 1982, for the Boston plant (two items of measuring and test equipment that were out of calibration date) did not address correction as to cause to prevent recurrence.
B.
Criterion XI of Appendix B to 10 CFR Part 50 states, in part, " Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions."
Contrary to the above, the BIW written quality assurance program did not require that adequate instrumentation be available for testing of safety-related equipment.
The BIW thermal aging facility at the Plymouth plant, used for safety-related qualification testing, did not have adequate instrumentation available to document or record oven temperatures during the thermal aging tests.
In addition there was not available in the LOCA simulation facility, instrumentation or other means to document that the specified electrical loads were applied to cables during testing.
C.
Criterion II of Appendix B to 10 CFR Part 50 states, in part, "The Quality Assurance program shall provide control over activities affecting the quality of the identified structures, systems and components, to an extent consistent with their importance to safety.
Activities affecting quality shall be accomplished under suitably controlled conditions."
Contrary to the above, the established quality assurance program did not comply with Appendix B to 10 CFR Part 50 in regard to providing necessary controls over applicable activities as evidenced by the following example:
Paragraphs 5.2 and 11.7 of the BIW QCM require the quality control department
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to review and approve test results of production tests; however, the QCM does not address safety-related equipment qualification test results.
Laboratory test report Nos. 820033, 82L006, and 82K020, which contain safety-related equipment qualification test results, show no evidence that they were reviewed and/or_ approved by the quality control department.
D.
Criterion X of Appendix B to 10 CFR Part 50 states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with documented instructions, procedures, and drawings for accomplishing the activity.
Such inspection shall be performed by individuals other than those who perform the activity being inspected.
Examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality."
Contrary to the above, although paragraph 10.4 of the BIW QCM requires that all inspections and tests be monitored by the quality control department for purchased material and manufactured products and that the results be documented on quality control department forms, the QCM does not address safety-related equipment qualification tests.
In addition, in the test laboratory areas at the BIW Plymouth plant, the only employees involved in the equipment qualification effort were the test technicians (who perform the test work) and there was no evidence of quality control department participation or monitoring of test or review of actual test data to determine or verify conformance to test plan / procedure requirements.
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