ML19351E903
| ML19351E903 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351E858 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8012190515 | |
| Download: ML19351E903 (4) | |
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3abco'ck & Wilcox Company Nuclear Power Generation Division Docket No. 99900400/80-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on July 7-11, 1980, it appears that certain of your activities were not conducted in accordance with j
NRC requirements.
A.
B&W's response to NRC inspection reports describe corrective actions and preventive measures and commits to completion of these actions in accordance with prescribed schedules.
Contrary to the above, B&W did not complete these corrective and preventive actions in accordance with their committed schedule.
The following are examples of this deviation.
1.
B&W letter dated May 19, 1980, responding to NRC Report 80-01, stated in part that:
... These OI's, (Operating Instructions) OI-1037 and 0I-1041 will be revised to eliminate conflicting requirements for record retention by June 15, 1980.
Contrary to the above, the subject OI's were not revised and were not superceded in the QA Operating Instructions manual as committed.
2.
B&W letter dated May 19, 1980, responding to NRC Report 80-01 states in part that:
.. The applicable OI's will be revised by June 15, 1980, to incorporate the (ANSI N45.2.12) requirements cited in this deviation.
Contrary to the above, all applicable OI's were not revised, nor was a newly revised Operating Instruction (01-1142, Rev. 4) issued'to incorporate the ANSI requirements as committed.
3.
B&W 1etter dated May 1, 1980, responding to NRC Report 79-04 states in part that: "(1)... Quarterly audi*.s of the HDL (Historical Documents List) will be conducted by the appropriate Task Engineers / Project Leaders' (T.E.) to determine if any errors exist
. during the first two weeks of each quarter of the year for audit, e.g. January, April, July and October.
, (2).
A written report will be made to the Release Administration Manager (by Release Administration personnel) for the results of each audit (of the HDL conducted by Release Administration personnel)
. audits (will be) completed before March 31.
. June 30.
Contrary to the above, audits to determine errors in past input of-the HDL were not conducted during the first two weeks of each quarter by all responsible Task Engineers nor were the two Release Administra-tion audit reports of errors in current input to the EDL completed before the March 31 and June 30 dates as committed.
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Criterion V of Appendix 3 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 accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acepetance criteria for determining that important activities have been satisfactorily accomplished."
Deviations from these requirements are as follows:
B.
Section VII A.1 of procedure NPG-0405-05 states that:
"The CVAR (Contract Variation Approval Request) is the supplier prepared, NPGD controlled, document used to approve disposition of those items or conditions identified by the supplier as not in compliance with the technical requirements of the procurement package or NPGD approved supplier documents." Appendix A (Flow Chart for processing nonconformances) indicates that the Task Engineer categorizes CVAR's as Category 1 (when) "... 4.c. (the) variations deviate from the requirement documents (as defined above and in procedure NPG-0412-56 (Processing of Design Specifications / Requirements Documents)
... (Then the Task Engineer) signs the CVAR, and submits all Category 1 CVAR's to the Integrator (Systems Engineer) for him to.
- review, (and)... resolve interface requirements on other affected tasks.
. (and) approve.
Contrary to the above, eight (8) CVAR's requesting approval to deviate from the technical requirements of the procurement package or NPGD approved supplier documents were either not categorized, or not categorized as Category 1 CVAR's, and therefore not submitted to the Integrator for review and approval as required by Procedures.
C.
Section V.A. of procedure NPG-0310-38 (Preparation and Maintenance of the Historical Documents List (HDL) states in part that:
"The HDL is a document history which provides identification, status, and relationship of B&W supplier technical and QA documentation for a particular NPGD product.
Contrary to the above, the HDL did not provide the document history (e.g.
correct status) of B&W supplier technical Contract Variation Approval Requests.
For example, CVARs 87-1019093-00, 37-0373-00,and 87-1145-00 were listed on the Historical Document List as "In House for Review," but these CVARs were found to be in the approved status i.e. review completed. Also CVAR 37-1018561 was listed as "In House for Review," but was found to have a
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disapproved status.
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D.
Section VII. A.4.a. of Quality Assurance Program Procedure NPG-0412-66, j
Product Upgrade List (PUL), states in part, that "The PUL is used to indicate known deficiences or known future required changes in a document i
or drawing at the time the document or drawing is released.
It is also l
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used to identify any higher tier document (input requirements) unavailable at the time of release.
Specific deviations from this procedure are as follows:
1.
Section VII. A.4.a. states in part, "Each of these deficiences shall be indicated along with the upgrade point (date or event). The method and source of upgrade (e.g., CI/A, issuance of conforming document, confor-mation of analyses, etc.) is completed with the signature and date of the cognizant Task Engineer to signify the resolution and accomplishment of the upgrade."
Contrary to the above, PUL 1002263-71D-0 was upgraded but not signed by the Task Engineer, and PULs 48-1166-01, and 02-1006273E-00 were upgraded with no method or source (basis) of upgrade listed.
2.
Section VII. A.4.b. states in part:
"The PUL and changes thereto shall be prepared and controlled by the cognizant Task Engineer."
Contrary to the above, PULs are not being controlled by the cognizant Task Engineer.
3.
Section VII. A.4.b. states in part:
"It (the PUL) shall be distributed to other affected Task Engineers, Project Managers, QA Engineer and the Buyer by Release Administration."
Contrary to the above, six (6) PULs (02-3738GF-00, 02-39095F1, 02-39097F2, 02-1002263-81D-0, 02-1006273E-00, 02-11009240-00) were identified by the inspector that were not identified for distribution.
4.
Section VII. A.4.b. states in part:
"A copy of the PUL, and (its) revision is attached to the master of the document and remains with the master until all items listed on the PUL are resolved."
Contrary to the above, copies of PUIs and revisions thereto are not accompanying (attached to) the master of the document when items on the PUL are unresolved. Masters of design drawings, quality require-ment matricies, and Applicable Document Lists, had no PULs or revisions thereto attached to them.
1 5.
Section VII. A.4.b. states in part: "For drawings and QRM's a notation is made in the margin indicating the existence of a PUL.
. and when all items on the PUL are resolved, the notation is erased from the margin of the QRM/ drawings."
Contrary to the above, (1) drawings 39095F1, 39097F2, and 170299C-2 had competion of PULs in the margin (erasing of letters PUL), but all three had undispositioned PULs on file for these drawings.
(2) Appli-
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cable documents list (ADL) 21-1003304-02 states drawing 02-37386F had no outstanding PUL on the document.
Contrary to this, an outstanding PUL 02-37386F-00 prepared July 7,1976 was discovered, and also drawing 02-37386-F had the letters PUL in the drawing margin.
6.
Section VII. A.4.b. states in part:
"The PUL must be revised and redistributed each time the document is revised until all items on the PUL have been resolveu.
. A copy of the PUL and its revision is attached to the master of the document and remains with the master until all items listed on the PUL are resolved."
Contrary to the above, a PUL, written on Quality Requirements Matix (QRM) 48-1166-01, was issued as Revision 3 but no copies of previous revisions could be found and no evidence of redistribution of Revision 3 was apparent.
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