ML20138J900
| ML20138J900 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20138J889 | List: |
| References | |
| REF-QA-99900404 NUDOCS 9705090157 | |
| Download: ML20138J900 (3) | |
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t NOTICE OF NONCONFORMANCE Wes$nghouse Electric Corporation Docket Nos.: 52-003 Pittsburgh, Pennsylvania 99900404 Based on the results of a Nuclear Regulatory Commission (NRC) inspection conducted on April 17,1997, of activities supporting Westinghouse Electric Corporation's AP600 design certification, it appears that certain activities were not conducted in accordance with NRC l
requirements.
A.
Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50, requires, in part, that measures be established to assure that conditions 64/erse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
WCAP-12600, "AP600 Quality Assurance Program Plan," Revision 2, dated December 15,1993, Section 16, " Corrective Action," states, in part, " Application of WCAP-8370 to AP600 activities includes the following:
The root cause of significant conditions adverse to quality are determined and documented, and the impact of such conditions on completed or related items and activities is evaluated."
WCAP-8370, Quality Assurance Plan (OA Topical Report), Revision 12A, dated April 1992, Section 16, " Corrective Action," states, in part, in:
Section 16.0, " General," that conditions adverse to quality such as failures, malfunctions, nonconformances, and out-of control processes (including failure to follow procedures) shall be identified. These adverse conditions are also analyzed, documented, and corrected commensurate with their importance to safety.
Section 16.1, " Corrective Action," that personnel performing activities in accordance with this plan identify conditions adver.
.o quality and suggest, recommend or provide solutions to the conditions e sopriate. For significant conditions adverse to quality, the causes are determint
, documented and the impact of such conditions on items and services is evaluated for significant trends and reported to the appropriate level of management.
Section 16.2, " Follow-up," that for corrective action resulting from reports (e.g.,
nonconformance reports, audit reports, computer software error reports, NRC inspection reports, customer audit reports, etc.) quality assurance participates in verifying that appropriate corrective action is documented and implemented.
9705090157 970502 PDR GA999 EMVWEST 99900404 PDR
Contrary to the above, Westinghouse:
1.
Did not identify, analyze, document, and correct conditions adverse to quality as required by the AP600 Quality Assurance program. During a July 1994 NRC structural audit of the nuclear island foundation mat, errors were identified in calculations performed by INITEC that resulted in significant re-design of the AP600 foundation basemat. The findings described in the August Im,1994, NRC " Summary of Audit of the AP600 Structural Design," report were not identified as a condition adverse to quality requiring or receiving quality assurance participation in verifying that appropriate corrective action is documented and implemented.
2.
Did not adequately determme and document the root cause of INITEC's basemat calculation errors nor evaluate the impact of such a condition adverse to quality on completed or related INITEC AP600 design deliverables j
and activities.
(99900404/97-01-01) l B.
Criterion Vil, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50, requires, in part, that measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors or subcontractors conform to the procurement documents.
WCAP-12600, "AP600 Quality Assurance Program Plan," Revision 2, dated December 15,1993, Section 7, " Control of Purchased items and Services," states, in part, " Application of WCAP-8370 to AP600 activities includes, but is not limited to, the following:
The initial qualification and subsequent performance evaluation of suppliers to which technical cooperation agreements [ emphasis added] apply is performed in the same manner as for suppliers of purchased items and services.
The perfoimance of each supplier is evaluated on an annual basis, commensurate with the complexity and importance to safety of items or services provided. The evaluation is documented and includes evidence, based on direct observation of work performed by the supplier, that the supplier's quality assurance program is continuing to operate successfully."
WCAP-8370, Quality Assurance Plan (OA Topical Report), Revision 12A, dated April 1992, Section 7, " Control of Purchased items and Services," states, in part, in:
Section 7.3, " Supplier Performance Evaluation," that "A formal evaluation of suppliers is performed each year to determine if additional actions such as audits are required during the upcoming year. This evaluation includes a review of some or all of the following: prior quality program audits, supplier surveillance activities,
...results of audits from other sources (customers, ASME, NRC, etc.)if available
[ emphasis added),...and the suppliers's responsiveness and cooperation in resolving
.=
quality questions or problems. As a result of this evaluation, suppliers requiring a complete quality program reaudit are identified...Regardless of the results of the evaluation, suppliers are reaudited every three years."
Contrary to the above, Westinghouse did not provide appropriate GA oversight of design activities performed by INITEC. After the basemat calculation errors were identified by the NRC in July 1994, Westinghouse did not evaluate or assess the impact of the errors on other work performed by INITEC. Specifically:
1.
Westinghouse failed to adequately evaluate or assess INITEC's annual performance, as required by WCAP-8370, Part B, Section 7.3, " Supplier Perfortwcce Evaluation," for a supplier of AP600 design deliverables that had been the subject of an adverse NRC audit finding.
2.
In its February 1995 triennial audit of INITEC, Westinghouse failed to conduct an evaluation of INITEC's response to Westinghouse's August 3, 1994, letter, and any associated corrective actions taken. The letter to INITEC described the basemat design calculation issues identified by the NRC du:,ng the July 1994 structural design audit. (99900404/97-01-02) l Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to 1
the Chief, Special Inspection Branch, Division of laspection and Support Programs, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance: (1) a description of the steps that were or will be taken to correct these items; (2) a description of the steps that have or v'iil be taken to prevent recurrence; and (3) the dates your corrective actions and preventative measures were or will be completed.
Dated at Rockville, Majr land i
This M day of naa,1997 3-