ML20039D234
| ML20039D234 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039D228 | List: |
| References | |
| REF-QA-99900762 NUDOCS 8112310444 | |
| Download: ML20039D234 (5) | |
Text
-
4 APPENDIX A NOTICE OF NONCONFORMANCE Nuclear Energy Services, Inc.
Docket No. 99900762/81-01 Based on the results of an NRC inspection conducted on October 20-23, 1981, it appears'that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
Criterion V of Appendix B to 10 CFR Part 50 states: " Activities affecting
_ quality shall be prescribed by documented instructions, procedures, or.
drawings, of'a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantita-tiv'e or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
j Nonconformances with these requirements are as follows:
A.
-QA Manual 80A9002, Section 18, paragraph 18.3.2 states in part, "The Quality Assurance Manager shall develop a written Quality Assurance Audit Schedule. The schedule shall cover one calendar year....
It shall provide for a formal audit of each section of the Manual at least once per year."
Contrary to the above, a review of all audits dating back to t
January lid 0, revealed that of the 18 sections listed,~only two.had been audited in 1980, (Design Control and Records) and three had been audited thus far in 1981 (Design Control and its various elements, Records, and Corrective Action).
B.
QA Manual 80A9002, Section 18, paragraph 18.3.3 states in part, " Audits shall be performed by NES auditors qualified in accordance with'a written procedure prepared by the Quality Assurance Manager...."
procedure No. 80A9026, " Qualification of Quality Assurance Program Audit Personnel,"1 paragraph 4.2.4 states', "The prospective lead auditor shall have participated'in a minimum of five QA audits... not to exceed.three years prior'to the date of qualification.
0ne of these audits shall be a nuclear QA audit withi.n the year prior.to the auditor's. qualification."
Contrary to the above,=the'audito'r performing audit No. 155 (Records) on
^
September 18, 1980, had not participated,in.any QA audits prior ~to that one.
He became' employed at NES in-Augus't 1980, was given a QA/QC Special-ist Examination on September 10, 1980,'and was certified as a Level II QA/QC Specialist-on September 17, 1980,"by the QA Managaer.
Because this individual was not qualified in accordance with the procedure, the only records audit performed in 1980 (identified in Item A) would be negated.
8112310444 8112163 PDR GA999 EECNESI!PDR -l 99900762
Nuclear Energy Services, Inc.
NES Division C.
Specification No. 80A9008, "Nonconformance Report Processing Procedure,"
paragraph 2.3 states in part, "NES requires suppliers to submit an SNR (Supplier Nonconformance Report) for approval for each nonconforming item supplier dispositioned as Repair or Use As Is.
The purpose of the SNR prepared by the supplier is to:... Identify the cause of the nonconformance and the corrective action to prevent recurrence." Para-graph 5.1 states, "The NES Quality Asswa",ce Manager shall perform Supplier audits as required to ascertain the supplier's complete com-pliance with the SNR disposition and corrective action."
Contrary ;J the above, a review of 14 welding SNRs submitted by NES's supplier who fabricated the fuel racks for Calvert Cliffs Nuclear Power Plant, Unit 1, revealed the following:
1.
In at least eight cases,-the cause of the:nonconformance is not iden-tified.
2.
In four cases, the preventive measures have not been addressed.
3.
A review-of related Suppl _ier. audits did not show that complete com-pliance with'SNR disposition and corrective action had been accom-plished and. verified.
D.
ASME Code Section IX, Article II,' paragraph QW-201.1 states in part, "The specific facts ~ involved in qualifying a WPS shall be recorded in a form called Procedure Qualification Record (PQR).
This form shall docu-ment the essential variables of the specific welding process or processes (as listed in QW-252 through QW-281), and the test results....
A change in any essential variable shall require requalification, to be recorded in another PQR."'
QA Manual 80A9002, Section 9, paragraph 9.3 states in part, " Vendor special process procedures, such as... welding,... to be used for i
NES items shall be submitted to and approved by NES when required..
Contrary to the above:
l 1.
A review of four supplier (Metal Products Corporation) WPSs, denoted i
as having been used on the Calvert Cliffs Nuclear Power Plant, Unit 1, spent fuel racks, and approved by NES on April 1, 1980, re-vealed that three of the four permitted unqualified changes in Section IX essential variables, i.e., GMAW WPS No. 233-3 and 237-2 allowed a change in the specified percentage composition of gas mixture from that which was qualified, and GTAW WPS No. 219-5 does not address preheat temperature, an essential variable.
2.
A review of two supplier (Selamco, Inc.) GMAW WPSs, approved by NES on July 8, 1981, and by Consolidated Edison Co. of N.Y., Inc.,
on September 14, 1981, for use on the Fuel Storage Rack Handling Tools for Indian Point Station, Unit 2, revealed that the WPSs allowed a change in an essential variable without being requalified.
Nuclear Energy Services, Inc.
NES Division.
F WPS Nos. A27 and SW-002' state-that the. mode of metal transfer is by the low voltage short circuiting arc method.. WPSs A27_and SW-002-show maximum base metal thickness ast2.0" and-1.0", respectively.
~
However, the PQRs show that the base metal test coupons were 1.5" and 0.5", respectively.
Section IX of the ASME Code limits section.
thickness to be welded for this process to 1.1 times the qualifi-cation coupon thickness.
Both WPSs' permit this' limitation to I
be exceeded.
E.
Quality Assurance Manual 80A9002 states in part, "... The Project Engi-neer shall prepare, obtain aprovals, and distribute a Quality Assurance Program Plan for each Project.
The Plan shall be-issued as early as practicable in the course of a Project...."
Contrary to the above, a Quality Assurance Program Plan for the Lacrosse-Boiling Water Reactor (LACBWR) Project was not issued as early as practi-t cable in the course of the project. The project started as early as 1974 and a QA Plan was not issued until June 1981.
~F.
Design Calculation Notebook Procedure 80A9004 states in part, "... Each calculation shall contain the following:
a.
Statement of the problem, b.
List of-applicable criteria.
c.
References ~to sources of data.
These include material and design standards', Customer documents and drawings, NES documents and t
drawings,.and~ formulas.
d.
Specific ~ assumptions, if a.ny.
e.
Detailed calculations.
f.
Computer Code,information (if applicable)...."
[
Contrary to the above,~ Design Calculations Notebook for Task ~5101-052 t
[
LACBWR Project did not contain statement' of the problem, list of appli-cable criteria,. references to sources of data and specific assumptions.
l:
G.
Design Calculation Notebook Procedure 80A9004 states in part "... Each l
calculation shall be independently checked by a qualified person...."
Contrary to the above, Battery Charger Equipment Anchorage Calculation (page 14) was not independently checked by a qualified person prior to issuing approved design sketch SK-5101-063-7 (LACBWR Project). The cal-culation still had not been checked as of October 21, 1981.
H.
Computer Code Documentation Control Procedure 80A9010 states in part,
"... A Master Code' List shall be prepared and maintained as part of-the Computer Code Document File.
The lic,t shall identify all codes and.
code versions which are on file.
"Each computer code file shall contain a Code File Index.
The index shall identify the contents of the file...
i.
"Each computer code maintained'as part of the computer code file shall be uniquely identified by a generic name and also as to version...."
Nuclear Energy Services, Inc.
NES Division,
Contrary to the.above, the Master Code List, Code File Index, and/or Code Identification was not maintained'as required for certain com-puter codes as follows:
a.
File for computer code ANSYS 'did.nat-co tain a Code File Index, b.
Master Code, Lis't did not identify all code versions for the ANSYS cnmputer code.
c.
Computer code KENO-IV. verification report identified code version four while the Master Code List identified code versions one and two.
d.
Code File Index for computer code KENO-IV incorrectly identifies the contents of the file in that no program manual is (ontained in the file as indicated by _the File Index.
I.
Quality Assurance Manuals, 80A9002 and 80A9021 respectively state in'part,
"... NES shall conduct periodic quality assurance training sessions for the instruction of key staff personnel e.g.; Project Engineers, Staff Specialists and Managers.
Instruction shall be given in the workings of the NES Quality Assurance Manual and Implementing Procedures....
. All technical personnel involved with Inservice Inspection activi-ties shall participate in indoctrination and training programs to become familiar with the purpose and intent of regulations, code, standards, and NES Quality Assurance documents...."
Contrary to the above, two engineering personnel on one project had not attended quality assurance training sessions where instruction was given in the workings of the NES Quality Assurance Manual and Implementing Pro-cedures, and four NDE technical personnel had not participated in indoc-trination and training programs to become familiar with the purpose and intent of regulations, codes, standards, and NES Quality Assurance docu-ments.
J.
SNT-TC-1A, June 1975 Edition, paragraph 10.2 states: "A terminated Level I and II employee may be recertified to his former NDT level by a new employer based on examination as described in Par. 8.2 provided all of the follo# ng conditions are met to the new employer's satisfaction:
a.
The unployEe has proof of prior certification.
b.
The employee was working in the capacity to which he had been certi-fied within six months of his termination.
c.
The employee is being recertified within six months of his termina-tion.
Nuclear Energy Services, Inc.
NES Division Contrary to the above, Procedure for Training and Certification of Nondestructive Examination Personnel, 99-CNTP-001, paragraph 11.4 states that personnel can be recertified within one year of termination which is six months in excess of the time specified in SNT-TC-1A, Junc 1975 Edition.
t I
l '
i s
F l'