ML20058Q264
| ML20058Q264 | |
| Person / Time | |
|---|---|
| Site: | 07100115 |
| Issue date: | 12/16/1993 |
| From: | Carr C BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312280145 | |
| Download: ML20058Q264 (9) | |
Text
_ _____ _ ______________
B&WFUEL COMPANY
[55
@ An Amencan Company with Wondwide Resource P.O. Box 11646 Lynchburg. VA 24506-1646 Telephone: 804-522-6000 December 16, 1993 U.
S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
Dear Sir:
REFERENCE:
REPLY TO NOTICE OF NONCONFORMANCE INSPECTION REPORT NO.
93210, DOCKET NO. 07100115 B&W Fuel Company (BWFC) respectfully submits written response to the nonconformances identified in the above referenced inspection report.
The corrective actions were provided by the contractor, Erie Engineered Products, Inc. (EEP), in which BWFC has concurred that their action is acceptable.
In addition, BWFC requested that EEP determine the root cause for each nonconformance.
After careful consideration of why the cited nonconformances occurred, it can be generalized that most of the nonconformances were attributed to personnel or documentation errors.
Procedural revisions and increased personnel awareness have been instituted to address these deficiencies.
Attachment I addresses each nonconformance in detail.
The corrective actions noted are complete as verified by a BWFC audit follow-up and the fabricated 51032-2 packagings meet the established design criteria.
Sincerely, B&W FUEL COMPANY Commercial Nuclear Fuel Plant 230041 C.
W.
Carr, Vice President, Manufacturing & Field Services cc:
Robert L.
Bear Chief, Source Containment and Devices Branch U.
S.
Nuclear Regulatory Commission Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Washington, D.C.
20555 pyj2280145931216
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ATTACHMENT I l
A.
10 CFR 71.107, " Package design control, " requires the licensee to establish measures to assure that applicable regulatory requirements and the package design are correctly translated into specifications, drawings, procedures, and instructions.
(~
Contrary to the above, a procedure for pressure testing each g
completed Model 51032-2 transportation packaging after y
painting, with the final closure gasket installed, was not available to the inspection team.
(1) description of steps that have been or will be taken to correct these items BWFC's intention for the final pressure test specification was to be performed prior to painting the packaging.
This criteria was misinterpreted by Erie Engineering Products (EEP).
EEP thought that the pressure test specification pertained to the packaging after it had been painted.
Due to this misunderstanding, the pressure tests that EEP performed were considered as in-process testing and were not in g
accordance with the specifications.
Since this error
)
was not identified until after the first seven packagings were painted, it was not possible to go back and perform the required tests in pre-paint condition for these seven packagings.
To rectify the nonconformance, BWFC revised the Model 51032-2 package fabrication specification document to require that a final leak test be performed after painting, with the final closure gasket installed.
EEP released a Leak Test Procedure to manufacturing on October 14, 1993.
To date, final leak testing has been performed on all 51032-2 containers, having successful results.
(2) description of steps that have been or will be taken to prevent recurrence In the future, it will be BWFC policy to perform leak testing prior to painting as a fabrication specification and after painting it shall be included as a part of the annual maintenance procedure.
(3) the dates your corrective actions and preventive measures were or will be completed.
Final leak testing of all 51032-2 containers, after painting with the final closure gaskets installed, was completed in December 2, 1993.
B.
10 CFR 71.111, " Instructions, procedures, and drawings,"
requires the licensee to prescribe activities affecting quality by documented instruction, procedures, or drawings, that they be followed, and that they include appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, the following instances were identified where procedures were not followed or were not adequate.
1.
A Scrap Material Log, as required for EEP Procedure No.
QCP-14, " Scrap Material," was not available to the inspection team.
(1) description of steps that have been or will be taken to correct these items A Scrap Material Log was generated by Erie Engineered Products, Inc., to cover the Cover Lift Bracket, PN 51032-2-170, which was scrapped and remade.
(2) description of steps that have been or will be ' xen to prevent recurrence The container fabricator, EEP, distributed a memo that required its inspection personnel to review the current QC Procedures to assure that all QC Procedures are bsing followed.
All 51032-2 components manufactured incorrectly and subsequently dispositioned as scrap, to include those identified prior to the development of the Scrap Material Log, will be noted on the Scrap Material Log.
(3) the dates your corrective actions and preventive measures were or will be completed.
Erie Engineered Products' Scrap Material Log was released for implementation on October 13, 1993 and was used throughout the fabrication process.
No other entries were required to be added to the log.
2.
Seventeen weld inspection points for Part No. 51032 003, " Cover Assembly," did not contain inspection stamps as required by EEP Procedure No.
QCP-13, " Issue and Control of Inspection Stamps."
(1) description of steps that have been or will be taken to correct these items At the time of the audit, the Inspection Records were in process and were not in the final form.
The records have since been reviewed and stamped by EEP QC inspection personnel, in accordance with
EEP Procedure No. OCP-13.
To date, all inspection records include the inspection stamp.
(2) description of steps that have been or will be taken to prevent recurrence EEP QC inspectors now carry inspection stamps on their person, and in-process inspections are stamped at the time of the inspection instead of at a process completion review point.
(3) the dates your corrective actions and preventive measures were or will be completed.
EEP QC inspectors were directed to carry inspection stamps on their person, effective october 13, 1993.
3.
The packagings in process did not contain weld stamps as required by EEP Weld Procedure No.
51032-2-802.
(1) description of steps that have been or will be taken to correct these items
\\
As required by 51032-2-802, the welder added their identification stamp to each 51032-2 container weldment.
(2) description of steps that have been or will be taken to prevent recurrence EEP's Manufacturing Manager was instructed to distribute a copy of the weld procedure to all weld stations and make the weld stations responsible for meeting the requirements of the procedure.
(3) the dates your corrective actions and preventive measures were or will be completed.
EEP's Manufacturing Manager was informed of the noncompliance on October 11, 1993.
EEP promptly responded by implementing the corrective action noted above.
4.
Documentation reflecting inspection and acceptance of packaging weld repairs was not available to the inspection team.
(1) description of steps that have been or will be taken to correct these items As noted in response to nonconformance A.,
EEP's xisinterpretation of the definition of the final leak 3
test specification resulted in the lack of documentation for the veld repairs.
Repair velds were performed in accordance with EEP procedure 51032-2-804, as part of the in-process leak test.
The leak test procedure data sheets were revised to add a column to indicate that re-inspection of the repaired welds was accomplished.
(2) description of steps that have been or will be taken to prevent recurrence Inspection of repaired welds is and will be documented on the revised in-process leak test data sheets.
(3) the dates yeur cor.ective actions and preventive measures were or wi.',1 be completed.
The revised leak test data sheets and procedure were issued to manufacturing on November 15, 1993.
Revised data sheets cover the second shipment of fabricated packagings.
C.
10 CFR 71.115, " Control of purchased material, equipment, and services," requires the licensee to establish measures to assure that purchased material, equipment, and services are procured from approved sources.
Contrary to the above, the supplier of calibration services to EEP, Cordavano Company, was not on the EEP approved suppliers list.
(1) description of steps that have been or will be taken to correct these items EEP did perform the required audit and determined that the Cordavano company was an approved supplier for calitration services for EEP.
However, an approved vendor: list was not available to demonstrate corpliacce.
EEP prepared and distributed a list of approved suppliers employed during the manufacture of the 51032-2 containers.
(2) description of steps that have been or will-be taken to prevent recurrence The EEP approved suppliers list includes the Cordavano Company.
Purchased material, equipment and services used for the fabrication of 51032-2 containers will continue to be procured from approved sources and the list shall be maintained as current.
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(3) the dates your corrective actions and preventive measures were or will be completed.
EEP's approved vendors list for the 51032-2 containers was supplied to BWFC on October 14, 1993.
D.
10 CFR 71.117, " Identification and control of materials, parts and components," requires the license to establish measures for the identification and control of materials, parts, and components.
These measures must assure that identification of the item is maintained by heat number, part number or other appropriate means throughout the fabrication, installation, and the use of the item.
These identification and control measures must be designed to prevent the use of incorrect or defective materials, parts and components.
Contrary to the above, full traceability of certain assembly hardware used in assembly was not maintained after the parts were issued to the assembly area.
(1) description of steps that have been or will be taken to correct these items The hardware that was reviewed on the Job Cart was pulled from the controlled hardware in the storeroom for three containers.
Following identification by the NRC inspectors that hardware on the 51032-2 container Job Cart was not properly traceable, all Job Carts applicable to the 51032-2 containers were identified with the purchase order number for traceability.
(2) description of steps that have been or will be taken to prevent recurrence EEP Stockroom personnel were instructed that the purchase order number must remain with the item (hardware) when the parts are drawn from stock.
(3) the dates your corrective actions and preventive measures vare or will be completed.
EEP Job Carts were tagged to identify the respective purchase order number on October 13, 1993.
E.
10 CFR 71.121, " Internal inspection, " requires the licensee to establish and execute a program for inspection of activities affecting quality to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
Contrary to the above, a set of support angle brackets were 5
modified and welded onto packagings without being inspected.
(1) description of steps that have been or will be taken to correct these items A Nonconformance Report (NCR) was generated to document EEP's inspection of the angle brackets for the rework of the angle brackets which was performed to eliminate the hole interference problem.
(2) description of steps that have been or will be taken to prevent recurrence EEP QC Inspectors were informed that the NCR must include the required inspection stamp for any rework instructions that are included on the NCR.
(3) the dates your corrective actions and preventive measures were or will be completed.
The angle brackets were inspected on October 7 and documented on the NCR on November 12, 1993.
F.
10 CFR 71.123, " Test control," requires the licensee to assure that adequate test instrumentation is available and used and to document the test results to assure that test requirements have been satisfied.
)
Contrary to the above, the following instance were identified where test control was not adequate.
1.
The measurement resolution of the pressure gauge used to conduct pressure tests, and its calibration, could not be verified.
(1) description of steps that have been or will be taken to correct these items The specified gage was not used due to the misunderstanding of the performance of the final leak test, refer to nonconformance A.
After it had been identified that the test being performed required that the gage meet the specifications, EEP used the specified gage type as confirmed by BWFC.
(2) description of steps that have been or will be taken to prevent recurrence BWFC clarified that the specifications must be met for in-process and final testing.
(3) the dates your corrective actions and preventive 6
measures were or will be completed.
The specified gage type was used for the final testing for the first seven fabricated packagings on October 20, 1993 and on the in-process on November 6, 1993 and final testing on December 1, 1993 for the last five packagings.
2.
Pressure test data for seven packagings showed that the actual high test pressure for two packagings was not documented, the time under pressure was not documented for six packagings, and the actual pressure drop after 30 minutes was not documented for any of the seven packagings.
(1) description of steps that have been or will be taken to correct these items This nonconformance also resulted from the misunderstanding addressed in nonconformance A.
EEP performed additional final pressure testing for all 51032-2 containers in accordance with BWFC's 51032-2 container licensing requirements and revised specification 08-1219403.
All containers succesatully passed the pressure testing.
(2) description of steps that have been or will be taken to prevent recurrence 1
EEP revised their leak test procedure for final pressure testing (see A.) and released a new procedure for in-process air pressure testing.
(3) the dates your corrective actions and preventive measures were or will be completed.
EEP's revised leak test data sheet was released to manufacturing on October 14, 1993.
G.
10 CFR 71.133, " Corrective action," requires the licensee to establish measures to assure that conditions adverse to quality are promptly identified and corrected.
The identification of the condition adverse to quality, the cause of the condition, and the corrective action taken must be documented.
Contrary to the above, a Corrective Action Log was not available to the inspection team.
(1) description of steps that have been or will be taken to correct these items 7
s The Corrective Action Log that is required in EEP's QC Procedure is for major nonconformances or repeat nonconformances.
EEP's QC Procedure allow corrective action to be noted on a Nonconformance Report (NCR) for minor nonconformances.
NCR*s applicable to the 51032-2 containers were all considered to be minor and the required corrective action is noted on the applicable NCR, thus, the Corrective Action Log is not applicable to the 51032-2 containers.
(2) description of steps that have been or will be taken to prevent recurrence EEP Inspection personnel were instructed to review the QC procedures as a general comment to assure that the procedures were being followed.
(3) the dates your corrective actions and preventive measures were or will be completed.
EEP requested their QC personnel to review procedures on October 13, 1993.
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