ML20205D865
| ML20205D865 | |
| Person / Time | |
|---|---|
| Issue date: | 10/08/1985 |
| From: | Clark A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hannum W ENERGY, DEPT. OF, IDAHO OPERATIONS OFFICE |
| References | |
| REF-PROJ-M-32 NUDOCS 8510170113 | |
| Download: ML20205D865 (12) | |
Text
f return to FBrown SS 396 Distribution;
/ Project ri-32 OCT 0 81985 W & LPDR NMSS R/F FCAF R/F RECunningham LCRouse Project M-32 ATClark NDavison KGreenaugh JKennedy JRoth, Reg I Dr. W. H. Hannum, Director PLohaus, Reg I West Valley Project Office FBrown (LA file)
Department of Energy-Idaho Operations Office P. O. Box 191 West Valley, New York 14171
Dear Dr. Hannum:
I have enclosed our report on our visit to the Project site to monitor your quality assurance activities during the week of July 29, 1985.
The topics covered were outlined in my letter to you dated May 29, 1985. We appreciate the cooperation given by the Department of Energy Project Office and its contractor, West Valley Nuclear Services, Inc., in responding to our inquiries and in providing all information requested.
Although no response to this letter is requested, we suggest that a meeting on the subject of our QA monitoring visit would be useful since additional information not examined in detail during our visit may be available. We will be interested in further information as your quality assurance program matures and the safety classification program is fully implemented.
Sincerely, M :,,t. f. g
- 4. % :,;.,
A. Thomas Clark, Jr.
NRC West Valley Project Manager Advanced Fuel and Spent Fuel Licensing Branch Division of Fuel Cycle and Material Safety
Enclosure:
As stated 8510170113 851000 PDR PROJ M-32 PDR A
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NAME:ATCiark:fb:LCous
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DATE:10/ 7 /85 : 10/V/85:
V 0FFICIAL RECORD COPY
e Monitoring Report on Quality Assurance Program for the West Valley Demonstration Project - August 1985 Introduction In accordance with the West Valley Demonstration Project Act, the Nuclear Regulatory Commission (NRC) is required to monitor tne Project from the stand-point of the health and safety of the public. On May 29, 1985, we informed the Department of Energy Project Office (DOE or the Department) of our intention to visit the Project site to monitor the effectiveness of tne implementation of the DOE contractor's quality assurance (QA) program. An earlier visit to observe a DOE-Idaho audit of the DOE contractor's QA program was undertaken in March 1983.
The Project QA Program was established by the DOE contractor, West Valley Nuclear Services, Inc., a subsidiary of the Westinghouse Electric Corporation, in accordance with DOE Orders 57CO.6A and 6B.
The Department has provided us with information on the contractor's QA program since its inception, including the Quality Assurance Methods and Procedures Manual and the Policy and Proce-dures Manual. On February 4, 1985, we were informed of the intent to establish a classification system for quality levels related to safety and service assurance. This quality classification system has been approved and is in the process of being implemented.
The intent of this report is to make recommendations, as appropriate, to the Department on possible improvements to the QA program for the Project based on our direct observation of your programs and experience with other QA programs.
In making observations during our visit, we considered the unique nature of the Project, both with respect to the technical approach taken and the ACTIONTRAK management scheme. Our intent was to focus on hardware quality in systems important to safety to obtain a " vertical slice" perspective of an item and its documentation as a demonstration of QA program effectiveness. We also examined previous audits both of and by the QA function. We note that the recommendations and observations are strongly skewed toward criticism. This is because we are reporting on exceptions or anomalies, rather than conformance to established critieria.
Indeed, in reading the detailed discussion it is seen that consider-able effective effort was observed both in the WVNS QA program itself and in the external audits by Westinghouse and DOE. Our comments need to be considered in this vein. We note that the effectiveness of the program has been aptly demonstrated by our initial observation in which we note strong evidence of quality in the CTS pad and liner.
In the sections below we provide our general observations and recommendations followed by a detailed discussion of each topic monitored. As discussed in the detailed sections of this report, we noted that previous audits by others, i.e., DOE, WVNS, and the Westinghouse Waste Technology Service Division, had already identified several of our observations and recommendations. Corrective actions on these items had already been initiated.
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2 Observations - Recommendations 1.
Based upon independent measurements and observations, the quality of the design, fabrication and installation of the CTS pad and liner was verified.
In addition, the QA documentation available was sufficient to provide evidence of the quality of those activities.
2.
The WVNS QA program does not currently include identification of struc-tures, systems and components to which it is applicable or the degree to which it should be applicable.
It was noted that a graded QA program, which will include the degree to which the program is applicable to all structures, systems and components, has been proposed.
Rapid implementa-tion of this graded program should be given high priority in order to improve utilization of available QA manpower directly in relation to safety importance.
3.
WVNS management should objectively assess its QA program implementation to assure it is properly focused on structures, systems and components which are important to safety.
4.
WVNS should examine the peer review process implementation which is conducted during equipment and system design to determine its adequacy.
5.
During " readiness reviews," WVNS QA should conduct a comprehensive review of the entire system in order to ensure that the system has been designed, fabricated, and installed in accordance with applicable drawings and documents.
C.
Some problem areas were identified in welding procedures and instructions provided to the work force.
7.
00E should improve the effectiveness of its audits by including personnel with expertise in the areas being audited on the audit teams.
8.
DOE should ensure, through audits at more frequent intervals, that prompt and effective corrective actions have been taken on deficiencies identified during previous audits. These audits should include a reaudit of deficient areas.
9.
DOE and WVNS should include the WVNS peer review process and the quality of hardware, equipment and their installation as part of the QA program effectiveness audits.
- 10. The WVNS QA group needs to ' identify and utilize specialists when auditing and conducting surveillances to assure that the QA program is effectively implemented.
- 11. WVNS QA personnel should be more effective in assuring that proper quality attributes have been identified for structures, systems and components important to safety by being more involved during equipment and system design, development and testing.
Engineering personnel shouir also be more alert to the need for properly specifying the quality at.ributes.
1 3
West Valley Nuclear Services Quality Assurance Program a.
Quality Assurance Program Review and Status The Department of Energy (00E) contractor, West Valley Nuclear Services (WVNS), a subsidiary of Westinghouse Electric Corporation, has written a Quality Assurance Program which conforms to the requirements of applicable DOE orders and the 18 criteria specified in ANSI /ASME NQA-11979. The WVNS QA program has been implemerned through the use of a series of WVNS policies and procedures and Qual
.y Assurance Methods and Procedures.
The program, as written, is applicable to all activities undertaken on the site and does not adequately identify those which are considered important to safety from those which are not.
This was identified previously by WVNS personnel and a revised program, which provides for a graded approach to the application of the quality assurance program, based on safety classifications and service classes, was prepared and has been submitted to DOE for approval. The proposed program offers WVNS the methodology by which the available Quality Assurance manpower can focus on activities and components important to safety. WVNS anticipates that this new program could be implemented by October 1,1985, if approved by 00E.
b.
WVNS Quality Assurance Staff The WVNS QA staff consists of the QA Manager, four QA engineers, the QA Operations Manager and six QA technicians. The work activities of the QA engineers include internal (onsite) audits, external (offsite) audits and participation in design reviews.
The work activities of the six technicians include surveillance of fuel shipments, receipt inspections, participation in audits, and all other activities taking place on the site.
Because of the large number of ongoing activities on the site, i.e., fuel shipments, 35 construction projects, design reviews, etc., the existing QA group appears to have an excessively large workload and has been placed in a reactive mode, despite having planned and established a schedule for audits and surveillances.
The NRC Monitoring Team observed that this problem should be somewhat mitigated if the proposed graded QA program, previously discussed, is approved for implementation.
c.
Qualifications and Training of Audit Personnel Through a review of WVNS records, it was determined that the QA group currently includes four properly qualified, trained and certified lead auditors. Two additional auditors are currently in training to become lead auditors.
In addition, twelve other persons.are trained and quali-fied as auditors and have been involved in the conduct of various audits.
However, the NRC Monitoring Team noted that there was limited expertise among the QA staff in certain areas, e.g., concrete placement and welding, and, therefore, the potential exists for inadequate audits in those areas.
4 This shortcoming was previously identified by WVNS and, as a result, arrangements have been made with DOE's prime contractor (Westinghouse) to provide qualified auditors on an as-needed basis when audits are conducted in those areas.
Quality Assurance Audits a.
DOE Audits Reports of DOE audits conducted at West Valley on August 14-17, 1984 and May 20-24, 1985, were examined by the NRC Monitoring Team to determine the scope and depth of the audits. The auditors were found to be organiza-tionally independent from the DOE and WVNS personnel at West Valley and were appropriately qualified to conduct the audits.
As a result of this examination, it was found that those DOE audits were sufficiently comprehensive to determine compliance of the WVNS QA program with the ANSI /ASME NQA-1 criteria and were effective in assessing the program and its implementation in the areas audited. However, it was judged that DOE audits are not sufficiently frequent to provide for the detection of a major programmatic problem, given the rapid pace of Project (ACTIONTRAK).
In addition, the two DOE audits did not cover all of the 18 QA program criteria. Criterion 11 and 13 were not included and cri-terion 8 and 9 were not completed.
During this monitoring visit, quality problems were identified in equipment and hardware with respect to cri-terion 9 and 13.
It was also noted that the DOE audit teams could have included additional technical expertise among team members in the areas being audited or more detailed audit plans should have been provided.
b.
prime Contractor (Westinghouse) Audits Reports of Westinghouse Waste Technology Services Division (WTSD) audits conducted at West Valley on May 22-23, 1984 and April 30 - May 2, 1985, respectively, were examined to determine scope and depth of the audits.
The auditors were organizationally independent from the DOE and WVNS personnel at West Valley and were appropriately qualified to conduct the audits. As a result of these audits, it was determined that the WVNS QA program has not been fully implemented and, therefore, was not fully effective.
However, the audit team found that WVNS had implemented surveillance and internal audit programs; design reviews were being formally conducted; and operations procedures for the Project were being developed in a timely manner.
In addition, the auditors determined that there did not appear to be sufficient quality planning and that the WVNS QA organization was functioning in a reactive mode. These findings were again noted by the NRC Monitoring Team during this visit. The WVNS response to these findings and actions to correct the identified deficiencies were being developed by WVNS during this monitoring visit.
5 c.
WVNS Audits 1)
Onsite Audits Through an examination of WVNS annual onsite audit schedules for 1983, 1984 and 1985, it was determined that six onsite audits were conducted during 1983 and six were conducted during 1984.
Ten onsite audits were scheduled for 1985.
One audit from 1983, one from 1985 and three from 1984 were selected at random and reviewed by the NRC Monitoring Team. The audits selected for review covered training, site administrative support, engineering, and construction management organizations.
It was found that audit plans and checklists had been prepared, audit findings and observations had been recorded and an audit report was issued to the responsible manager of the organiza-tion audited.
2)
Offsite Audits Through an examination of WVNS annual offsite audit schedules for 1983, 1984 and 1985, it was determined that four offsite audits were conducted during 1983, five during 1984 and five were scheduled for 1985. One audit from 1984 and one from 1985 were selected at random and reviewed. The 1984 audit included a review of the Ebasco design review organization and the 1985 audit involved a review of equipment being fabricated for the Project by the NUCRALOY Corporation.
It was found that audit plans and checklists had been prepared, audit find-ings and observations had been recorded and an audit report was issued to the responsible organization.
3)
Onsite Surveillance Surveillance of ongoing onsite operations and maintenance activities was initiated approximately 21 months ago. The QA Operations Manager maintains a master list for scheduling. The surveillances are scheduled on an as-needed or routine (monthly or quarterly) basis.
Each QA technician is scheduled to conduct surveillance activities.
Currently, four of the six technicians are scheduled to conduct surveillance of the ongoing spent fuel shipment activities, leaving only two to conduct surveillances of other onsite activities when l
shipments are made.
QA technicians performing surveillance activities, utilize a form,
" Request for Corrective Action" (RCA), to record defects and non-l compliances. The RCA forms are logged and tracked to assure that corrective actions are implemented and completed.
Hardware Review and Examination l
Quality aspects of those structures, systems, and components important to safety were reviewed by the NRC Monitoring Team. The structures, systems and i
[
6 components selected for review included portions of the Component Test Stand (CTS), the Cement Solidification System (CSS) and the Supernatant Treatment System (STS).
a.
Component Test Stand (CTS) 1)
Melter Off-Gas System An indepth review of the melter off gas system design control was conducted. The review was conducted to determine the following:
Design inputs, such as design bases, performance requirements, codes and standards were identified, documented, and their selection reviewed and approved.
Design activities were prescribed and accomplished in accordance with procedures that would assure that applicable design inputs were correctly translated into specifications, drawings, pro-cedures and staffed with qualified and trained personnel.
The Monitoring Team determined that the system design and performance requirements were documented in design criteria WVNS-DC-015, " Design Criteria Melter Off-Gas Treatment System and Vessel Ventilation System," Rev. 0 (Draft).
Due to the nature of the project, the system design is still in the evaluation process. The design will be finalized after the completion of cold testing. As part of design process, a safety analysis is being performed in parallel with the system design. Design changes / modifications will be incorporated if the safety analysis warrants it.
The Monitoring Team found that the design information was disseminated freely among the cognizant design groups.
Interfaces were smooth and efficient. The design reviews for the system and most of its components were performed in accord-ance with WVNS Policy and Procedure WV-360, " Design Review Procedure."
However, at the discretion of the cognizant design manager, the review process may be changed to WV-104, " Design Document Review Form." WV-104 provides for a less comprehensive design review based on the judgement of only that individual responsible for the design.
A review of the minutes of the design review committee indicated that the contents were comprehensive and review team members were knowl-edgeable and qualified.
The Monitoring Team independently verified that line sizing as documented in the design calculation was consistent with design requirements. However, discrepancies were noted in 8 out of 40 lines sampled. Although the discrepancies were generally minor in nature, it indicated that the WVNS peer review process needs to be strengthened.
The off gas system's cold test program has been planned. Test procedures including test requirements and acceptance criteria were properly documented. System operation guidance (Run Plan 0G-64-1,
.)
7
" CTS Off-Gas Systems - FACTS Operation," dated July 1985) was found consistent with the design package.
Quality Assurance involvement in this system's design process was found to be limited, i.e., only in attending design review meetings.
No QA audit has been performed on this system.
The Monitoring Team attributed this to a lack of quality planning, e.g.,
no quality lists for QA follow-up, especially considering the current fast pace of the design process (ACTIONTRAK).
On the basis of the above review, the Monitoring Team concluded that design engineering personnel are qualified and experienced. Appli-cable information derived from experience and scale model test results, along with environmental and safety analyses, were kept updated in the design process.
The cold test package and operational instructions were well prepared and planned.
However, QA's involve-ment in the design process was found weak.
Lack of a Q-list which provided a graded approach for the application of the QA program, especially in the design control area, is thought to have contributed to this weakness.
2) pit Liner The CTS pit liner was determined by the Monitoring Team to be 10 gauge, Type 304L stainless steel, attached to embedded stainless str.el structural steel and studs.
The gas metal arc (GMAW) welding prccess, using 308L electrodes, was the primary welding process, with the gas tungsten arc (GTAW) welding process used for a portion of the weld!ng.
Through independent measurements by the Monitoring Team, the overall condition of the as-installed liner, including butt welds, corner attachments and liner to stud welds, was observed. Ultrasonic (UT) thickness measurements were made at liner to embedded stud welds, butt welds to embedded structural material and of the liner thickness.
No deviations were found from the pit liner specification or engi-neering drawings.
Documentation of the pit liner requirements, as-built drawings, material certifications and construction specification were reviewed.
No problems were identified.
Review of documentation indicated that QA personnel were involved in specification review a~nd surveillance activities during the design, purchase order preparation and installation of the CTS pit liner.
In addition, QA evaluated the contractor installing the liner to assure that the applicable criteria of NQA-1 were adhered to.
i
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3)
Welding of Piping for the Component Test Stand (CTS) and Cement Solidification System (CSS).
Samples of shop and field pipe welding, both completed and in progress, were examined by the Monitoring Team to evaluate the con-formance of the welding contractors to the requirements of ANSI B31.3 and the ASME Code Section IX to which the West Valley Project has been committed. Welding procedures, welding qualification practices, weld electrode or filler metal selection, weld shielding gas selection, weld material control and weld appearance were observed as specific topics in the welding activity on the CTS and CSS piping.
The purpose of these observations was to establish if weld work was being accomplished within the requirements established by the Project Engineering Group. The CTS and CSS piping examined was utility (air and water) and low level radioactive process piping.
High level radioactive piping was in the design stage with none either fabri-cated or installed.
The work of two contractors was not found to fully meet the requirements of ANSI B31.3, ASME Section IX and/or specific WVNS or subcontractor welding procedures provided to the work force.
Problem areas identified are listed below:
Contractor Problem Reference A
Wrong Weld Material WP 1.14 316L vs 308L A
Use of N Backup Gas for WP 1.14 GTAW of 304L piping where Argon is specified A
Various weld materials No weld material available to craft workers control procedure B
E6010 electrode held in ASME SFA 5.1, Table AI oven with E7018 B
Various weld materials No weld material available to craft workers control procedure B
Omission of Purge Gas on WP 1.14 stainless pipe butt joint welding B
GMAW WP 1.14 allows 2T ASME IX provides maximum thickness to be maximum thickness to welded (Short Arc) be welded of 1.1T QW 403.10
9 Contractor Problem Reference B
Omission of welding rings WVNS-PI-005 where required by CTS Part 3.07 specification B
Shipment of pipe assemblies CTS letter dated with unacceptable visual 4/3/85 Foreman / Welder inspection conditions responsible for examining welds 8
The qualified welder list Good welding practice does not indicate the procedures each welder is qualified to The above findings indicate problems in several areas.
Translation of written requirements to instructions to workmen.
Not following welding procedures.
Incomplete attention to specification details or not initiating specification revisions to allow method improvements.
The gas metal arc (GMAW) welding process in the short arc mode, when used for other than root pass welding with proper root edge geometry, is subject to weld joint sidewall lack of fusion defects.
It is the opinion of the Menitoring Team welding specialist, as supported by weld indussey experience, that the short arc process is an inappropriate process selection for the through wall welding of carbon or stainless steel pipiag 3/8" in thickness or greater. This position is taken even though quali-fi:ation is possible to the rules of the ASME Code Section IX for both the procedure and welders. Therefore, the WVNS site is cautioned to limit the use of GMAW in the short arc mode to pipe to pipe root welding and then only with properly prepared weld joint bevels.
QA attention to job factors other than comparison of ongoing work to specification and procedural requirements.
Although the above problems were identified, the Monitoring Team welding specialist noted that external surfaces of installed piping welds were generally good in visual appearance, indicating the use of qualified, competent welders.
The ANSI B31.3 Code in Chapter VI describes the requirement for an Owner's Inspector to be involved in implementation of ANSI B31.3.
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10 The Owner's Inspection function, if in place, would most likely identify problems such as those listed above.
The WVNS QA function has a responsibility for surveillance in the piping installation and welding areas. However, based upon the above Monitoring Team finding, it was not found to be effective in assessing that requirements were translated into actual work tasks.
The condition where the Owner's Inspector is not designated as per the B31.3 Code is cc..idered to be a weakness in performing adequate overview of B31.J work.
4)
Preoperational Testing - Melter and Related Equipment The melter and related equipment will be fully tested and evaluated prior to operation with radioactive material (hot operation).
The cold test program will include component testing and feed stream simulation.
Preoperational testing will also include a significant research and development effort to establish details of the operating conditions and variables as well as establishing equipment reliability.
The preoperational testing program was reviewed by the Monitoring Team during discussions with members of the WVNS staff.
Component testing is in progress for those components which are in place, including the melter, turntable, and the submerged bed scrubber.
Equipment checks and preoperational testing has been and will be per-formed as each component becomes operational. The second phase of testing is to evaluate process variables including feed stream vari-ables and melter temperature. Cold operation, without radioactive material, phase three of the preoperational testing, will provide operational time using actual process conditions prior to hot opera-tion with radioactive material.
The melter will be operated for approximately three years prior to hot operation. The preoperational testing will also include an evaluation of system components prior to the conclusion ~of cold testing to determine which, if any, items should be rebuilt or replaced prior to initiation of hot operation.
It will be important for QA to closely monitor the work at that time to assure a quality product, as well as a safely operating system.
b.
Supernatant Treatment System (STS) 1)
STS Design Status The Supernatant Treatment System (STS) is being designed to extract certain radionuclides (primarily cesium) from the alkaline salt solu-tion held in Tank 8D-2.
This system will be the first system at the site put into hot operation.
The system functional and operational requirements were based on sound laboratory test results and engineering evaluations. The detailed design work is currently being performed by the WVNS subcontractor, EBASCO Services. The design calculation package has not been released to WVNS by the designer and
11 was not available for review during this monitoring visit.
Therefore, no substantive review of hardware and components could be completed by the Monitoring Team during this visit.
2)
Electrical / Instrumentation (E/I)
Through a review of the design criteria package prepared by WVNS for the STS, the monitoring team determined that the E/I criteria speci-fied did not appear to be adequate in that only general building code criteria had been specified. As a result, WVNS quality assurance did not have specific attributes established as, for example, in the ANSI N45.2.4 or IEEE 336 documents, to assure that the adequacy of the system design can be measured.
A similar observation was made with respect to the melter system (CTS) components.
Nonconformance Reports Nonconformance reports related to the installation of the Component Test Stand foundation (concrete placement) were examined by the moni-toring team. WVNS records indicated that the status of each noncon-formance report was well documented, adequate corrective actions were taken and each nonconformance report was properly closed out.
Unusual Occurrence Reports WVNS has established an Unusual Occurrence Reporting (UOR) System in accordance with DOE ORDER 5484.2. A numbering system is utilized to indicate the facility, the calendar year, the sequential report identification number, an area designation, and a sequential number for that area. Area designations identify the specific areas of the site where an unusual occurrence takes place for tracking purposes.
After issuance of the initial report of an unusual occurrence, an interim report is issued after 30 days if all actions have not been completed and a final report is issued af ter all corrective actions have been completed. The UOR form is initiated by the department responsible for the area in which the incident occurred and is approved by the affected departmant manager, the Manager, Environ-mental and Occupational Safety (EO&S) and the Manager, Quality Assurance. Approval by the Manager, E0&S, indicates that proper actions have been taken and approval by the Manager, QA, indicates that all corrective actions have been completed.
Unusual occurrence reports for the time period January 1, 1984 through June 7,1985 were examined by the Monitoring Team.
In all cases, the incidents were adequately described in the reports, immediate evaluations were conducted, immediate corrective actions were taken, and, in most cases, final evaluations were completed and permanent corrective actions were taken. However, the closecut of several UOR's was being held up pending resolution of facility-wide problems which appeared to be generic in nature and not specific to the incident discussed in the UOR, i.e., implementation of the graded Quality Assurance Program previously discussed.