ML20041F163
| ML20041F163 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20041F157 | List: |
| References | |
| REF-QA-99900531 NUDOCS 8203160247 | |
| Download: ML20041F163 (4) | |
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APPENDIX B NOTICE OF NONCONFORMANCE Nuclear Power Services, Inc.
Docket No. 99900531/81-01 Based on the results of an NRC inspection conducted on November 17-20, 1981, it appears that certain of your activities were not conducted in accordance with NRC requirements.
A.
Criterion II of Appendix B to 10 CFR Part 50 states in part that,
"... activities affecting quality shall be accomplished under suitably controlled conditions.
Controlled conditions include... assurance that all prerequisites for the given activities have been satisfied...
The program shall take into account the need for special... skills to attain the required quality."
Contrary to the above, the Nuclear Power Services, Inc., (NPS) quality assurance program did not take into account the need for special skills to attain the required quality, nor provide assurance that all prerequisites for design activities had been satisfied, in that the NPS Personnel Qualification and Verification Program procedure (EPP-2) does not provide assurance that personnel hired to perform nuclear safety-related design and analysis actually possess the special skills and technical qualifica-tions (education, training and experience) needed to perform the analyses in a planned, controlled and correct manner.
See inspection report section D.2 for details.
B.
Criterion XVII of Appendix B to 10 CFR Part 50 states in part that,
... Sufficient records shall be maintained to furnish evidence of activities affecting quality... The records shall also include closely related data such as qualifications of personnel...."
Section 17.0.4 of the NPS Quality Assurance Manual states in part th t,
... QA Records shall be stored in separate and secure storage loca-tions or in a single fire and water proof area...."
Contrary to the above, QA Records of Personnel qualifications, indoctri-nation, arid training, needed to furnish evidence that suitable skills and proficiencies were achieved and maintained by personnel performing acti-vities affecting quality, were not stored in separate and secure storage j
locations, or in a single fire and water proof area.
C.
ANSI N45.2.11, Draft 2, Revision 2, dated May 1973 was imposed on NPS by l
NPS Industries, Inc. (NPSI), via purchase order 30-086 dated September 11, 1978, which incorporated Gibbs & Hill (G&H) specification 2323-MS-46A.
i I
Section 7.0 of ANSI N45.2.11 states in part that, " Documented procedures j
shall be used to control issuance of design documents and changes thereto.
These procedures shall assure that documents, including changes, are j
reviewed for adequacy and approved for release by authorized personnel l
8203160247 820218 PDR GA999 EEC ** **
- 99900531 PDR
Nuclear Power Services, Inc. Contrary to the above, documented procedures did not assure that docu-ments, including changes, were reviewed for adequacy and approved for release by authorized personnel.
Specific examples of the nonconfor-mance are as follows:
1.
Changes to drawing 25-8748 and calculation SC-141-2-31 were not reviewed for adequacy by authorized personnel as evidenced by the signatories of unknown individuals on the documents as the reviewers /
checkers of the documents.
2.
The individual identified as the originator of Revision 1 to page 175 of calculation SC-265-2E-709 on the QA record copy of the cal-culation was not the same individual identified as the originator of Revision 1 on the original of the calculation that was retained by the design department.
D.
Sections 7.0 and 8.0 of ANSI N45.2.11, state in part that, "... -(de-sign) changes shall be justified and subject to design control measures commensurate with those applied to the original design... changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval...."
Contrary to the above, drawing 25-510-R1 was changed on December 26, 1979, without justification and pages 154,155,174 and 175 of calculation package SC-265-2E-709 were changed on April 18, 1981, without being re-viewed and approved by the same organizations that performed the original review and approval.
E.
Section 4.2 of ANSI N45.2.11 states in part that, " Analyses shall be sufficiently detailed as to purpose, method, assumptions, design irput, references, and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without recourse to the originator."
Contrary to the above, analyses were not sufficiently detailed as to pur-pose, method, and assumptions in that the basis for sizing the fillet welds that were used in six examined structural calculations could not be determined by an appropriately qualified NRC inspector, without recourse to the originator.
Nuclear Power Services, Inc. F.
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 quanti-tative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Contrary to the above, activities affecting quality were not being accom-plished in accordance with documented instructions, procedures or draw-ings.
Specific examples of this nonconformance are as follows:
1.
Sections 1.0 and 3.3 of NPS procedure EPP-2 state in part that, "This procedure establishes measures to assure that personnel engaged in quality-related activities are qualified to perform the duties to which they are assigned... the Personnel Verification Super-visor (PVS) is responsible for implementing this procedure." These measures include obtaining and maintaining complete, accurate and current records, and that the Vice President of Engineering be in-formed of inconsistencies or anomalies related to an applicant's qualifications.
Contrary to the above, the PVS did not implement, nor cause to be implemented, all of the established measures to assure that personnel engaged in quality-related activities were qualified to perform the duties to which they are assigned in that, records contained in 16 examined personnel folders were incomplete, inaccurate, noncurrent, and were not brought to the attention of the Vice President of Engineering when anomalies in applicants education or experience qualifications were identified.
(See inspection report section 0.2 for details.)
2.
Section 17.0.4 of the NPS QA Manual states in part that, "The Manager of Quality Assurance shall prepare a Master List of NPS QA Records
... which shall include non project records and generic project records.
The Project Manager shall prepare a Project QA Record Index which incorporates those generic project records applicable to the scope of work and any additional records required by the client.
Contrary to the above, the TUSI Project QA Record Index did not identify nor incorporate, NCRs, CARS, Procurement Documents and QA Package Review Checklists as generic project records, even though they were identified as such on the Master List of NPS QA Records.
4
Nuclear Power Services, Inc. 3.
QA Manual Section 15.0.4 states in part that, "Nonconformances may be revealed by internal checking or audits, design reviews, or by the client.
When so revealed, the responsible NPS manager or supervisor shall initiate a Nonconformance Report (NCR).
Contrary to the above, an NCR was not initiated by the responsible NPS structural group supervisor after the identification and documenta-tion in an inter-office memo dated April 28, 1980, that fillet welds in component supports were undersized with respect to ASME Code requirements.
As a result, action was not initiated to correct existing drawing and calculation deficiencies or preclude their recurrence as required by section 9.0 of ANSI N45.2.11.
4Property "ANSI code" (as page type) with input value "ANSI N45.2.11.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Section 3.0.5 of the NPS Quality Assurance Manual states in part that, " Design Verification shall be performed to assure that the design meets the specific design criteria...."
Contrary to the above, the design verification of pipe support No.
CT-2-007-404-522R did not assure that the design met the specific design criteria in that the design verification did not disclose that the tensile and shear force design inputs to the NPS baseplate analysis computer program were transposed.
5.
Subsection NF of Section III of the ASME Code was imposed on NPS by NPSI purchase order 30-086 dated September 11, 1978.
Paragraph NF-3292 of the Code states, "The permissible types of welded joints used in linear type supports shall be as stipulated in XVII-2450." Appendix XVII-2452.1 states in part, "In joints connected only by fillet welds, the minimum size of fillet weld to be used shall be as shown in Table XVII-2452.1-1.
Weld size is determined by the thicker of the two parts joined, except that the weld size need not exceed the thickness of the thinner part joined..." Table XVII-2452.1-1 specifies that a 5/16" fillet weld is required for material thicknesses greater than 3/4" up to 1 ", and that a 3/8" fillet weld is required for material thicknesses greater than 1 " up to 2\\".
Contrary to the above,15 examined component support drawings specified fillet welds, to be welded at the Comanche Peak Steam Electric Station (CPSES) Unit 2 site, that were not in accordance with ASME code requirements.
The material was shown to be up to 2" thick which requires the use of fillet welds up to and including 3/8"; however, all such fillet welds were specified as 1/4".