ML19242C322
| ML19242C322 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1979 |
| From: | Foster W, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19242C296 | List: |
| References | |
| REF-QA-99900358 NUDOCS 7908100260 | |
| Download: ML19242C322 (12) | |
Text
U.S. NUCI.EK1 REGUI.ATORY COBBIISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No 99900358/79-01 Program No. 51400 Company:
ESB, Incorporated Exide Industrial Battery Division 101 Gibraltar Road Fsrsham, Pennsylvania 19044 Inspection Conductid:
May 1-4, 1979 Inspectors:
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/,,, W. E. Foster, Contractor Inspector Dite /
Vendor Inspection Branch f
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. &%JA 547/79 D. M. Hunnicutt, Chief, Components Dite Section II, Vendor Inspection Branch Approved by:
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f/7/7 7 D. M. Hunnicutt, Chief, Components Da'te /
Section II, Vendor Inspection Branch Summarf:
Inspection on May 1-4, 1979 (99900358/79-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix 3 criteria, and applicable codes and standards, including organization; procurement docu-ment control; and change control. An initial management meeting was also conducted.
The inspectica involved thirty-six (36) inspector-hours on site by two (2) NRC inspectors.
Results:
In the three (3) areas inspected, no apparent deviations or unresolved items were identified in two (2) areas; the follcwing deviation and unresolved items were identified in the remaining area.
Deviaticn:
Change Cc:. trol - Measures had not been established to identify personnel authorized to review, approve and release engineering documents 7 9081002cc m) O l
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2 required by Criterion VI of Appendix A to 10 CFR 50, and paragraph 3.4.1 as of the Quality Assurance Manual (Enclosure).
Unresolved Items: Change Control - (1) The QA Manual and a QC procedure are not consistent regarding personnel authorized to initiate quality documents; (2) QA approval of manufacturing requirements appear on design notices rather than on canufacturing requirements; and (3) Engineerit documents are distributed in accordance with a distribution list other aan the one identified in a design engineering procedure (DetailsSection I, paragraph B.3.b.).
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DetailsSection I (Prepared by W. E. Foster)
A.
Persons Contacted
- A.
P. Abbott, Executive Director - Marketing W. J. Horner, Supervisor - Design
- W. E. T.
Jones, Chief Engineer C. R. McAdoo, Engineer - Decamantation
- C. K. McManus, Ma rket Manager - Stationa ry D. E. Mulford, Manager - Product Development R. H. Schweers, Supervisor - Operations H. L. Sherwood, Manager - Process Control
- M.
M. Stanton, Diree tor - Design Engineering E. M. Strohlein, Manager - Application and Service
- R.
B. Thomas, Assistant Director - Purchasing
- A.
J. Ushka, Director Quality Assurance
- J. F. Vinkler, Manager - Quality Assurance (Horsham)
- G.
R. Wallis, Vice President and General Manager A. G. Warne, Director - Purcha-ing
- Attended Exit Interview B.
Change Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Eesign changes, including field changes, had been approved by the orgacization that originated the design, or a desig-nated respcasible organization.
b.
Measures had been established to control deviations from quality standards which had been specified and made a part of design documents.
c.
Measures had been established to control changes to docu-ments, such as instructions, procedures, and drawings, which prescribed all activities affecting quality and assured that changes had been:
(1) Reviewed for adequacy and approved for release by authorized perscanel, n
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(2) Distributed to and used at the location where the prescribed activity is performed, (3) Reviewed and approved by the organizations that per-for=ed the original review and approval, or a desig-nated responsible organization.
d.
Measures had been established to control materials, parts, or components which did not conform to requirements.
2.
Methods of Accomplishment The preceding objectives were acccmplished by:
Review of the following custtmer orders and attendant docu-a.
ments to verify that requirements for software and hardware changes had been invoked.
(1) The Cleveland Electric Illuminating Company Contract Number P-1480-3, Confirmation of Award Letter, dated September 15, 1977; and (2) Stone and Webster Purchase Order Number NA-3192, dated July 26, 1978.
b.
Review of the following documents to verify objectives la.
through Id. above:
(1) Quality Assurance Manual, Revision 8, dated January 27, 1979; Sections 3, 5, 6, 10, 11, and 15.
(2) Quality Control Procedures, Numbers 55.0, dated Ja nua ry 23, 1976; 62.0, dated December 31, 1975; and 62.1, dated October 10, 1977.
(3) Eesign Engineering Procedures, Numbers S-25.CS.1, dated July IS, 1973; S-25.03.2, dated July 18, 1973; S-25.10, dated November 1974; S-25.10.1, dated October 1973; S-25.11, dated October 1973; S-25.11.1, dated May 2, 1975 ; and S-25.13.1A, dated February 1977.
(4) Design Notices and related documents for: Bill of Material (SM) No. 67167, dated July IS, 1977; BM 69642-HS, dated Februa ry 15, 1978; Drawing Numbers MC-S2238/96, dated May 13, 1976; MC-82234, dated May 12, 1976.
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5 (5) Manufacturing Requirements Nos. 102 - Section 2.2(R)(S),
dated January 26, 1979; 101 - Sect'.n 1(R), dated July 12, 1978; and 103 - Section 1(S), dated March 2, 1979.
(6) Temporary Manufacturing Requirements Numbers:
14.1, dated May 16, 1978; 17.1, dated March 3, 1977; and 18.1, dated May 6, 1977.
(7) Engineering Specification Number 6.5.0, dated September 28, 1978.
(8) Purchase Requirements Numbers:
1 Section 1, dated November IS, 1976; 1 Section 3, dated March 28, 1978; and 23 Section 1, dated January 30, 1979.
3.
Findings a.
Deviation from Cctaitment (1) See Enclosure.
(2) Informal, undated, handwritten procedures existed for controlling temporary manufacturing requirements,
purchase requirements, and manufacturing requirements.
Also, the review / approval block for these documents indicated position titles of reviewers / approvers.
b.
Unresolved Items (1) An inconsistency exists between paragraph 6.4.2 of Revisica 8 of the Quality Assurance Manual, dated January 27, 1979, and paragraph 5.1 of Quality Control Procedure Number 55.0, dated January 23, 1976. The latter indicates that quality documents shall be pre-pared by any responsible QA perscanel while the former indicates quality documents shall be initiated by any respcasible person.
(2) Paragraph 5.4 of Quality Control Procedure Number 55.0, dated January 23, 1976, indicates QA approval shall appear on documents identified as: Manufacturing Requirecents, Temporary Manufacturing Requirements, Engineering Specifications, and Purchase Requirements.
However, QA approval signature appears on the Design Notices for Manufacturing Requirements rather than on the Manufacturing Requirement.
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6 (3) Rcutine Orders, Design Notices, Bills of Material, Assembly and Tray Drawings are distributed in accord-ance with a Distribution List other than the one identified in Design Engineering Procedure Number S-25.11.1, dated May 2, 1975.
c.
Comments (1) The Cleveland Electric Illuminating Company letter to ESB, Incorporated, dated September 15, 1977, confirms award of contract P-1480-B and requires implementation of Exide's Quality Assurance Manual, Revision 7, dated May 5, 1977.
The Quality Assurance Manual is currently at Revision 8, and Revision 7 had not been maintained on distribution for implementation on contract P-1480-B.
(2) The identified custcmer orders invoked the requirements for control of changes to software and hardware.
C.
Exit Inc a rview 1.
The inspectors met with management representatives denoted in paragraph A. at the conclusion of the inspection on May 4, 1979.
2.
Tha following subjects were discussed:
a.
Areas inspected.
b.
Deviation identified.
c.
Unresolved items identified.
d.
Response to the report.
Exide Management was requested to structare their respctse under headings of corrective action, preventire measures, and dates for the deviation.
3.
Shaagement ccaments were related generally to clarification of the findings.
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7 DetailsSection II (Prepared by D. M. Hunnicutt)
A.
Persons Contacted
- A. J. Ushka, QA Direc:or D. J. Bouquard, Senior Buyer
- Denotes those persons who attended exit interview.
B.
Initial Management Meeting 1.
Objectives The objectives cf this meeting were to accomplish the following:
Ta meet with the Exide Power Systems Division (Exide) manage-a.
ment and those persons responsible for the administration of the Quality Assurance Program, and to establish communica-tions chaanels.
b.
To determine the extent of Exide's involvement in the com-mercial nuclear power plant business.
To discuss NRC direct inspection program, including the c.
Licensee Contractor and Vendor Inspection Program (LCVIP) organization, the Region IV organization and the related NRC organization.
d.
To describe the LCVIP inspection methods and documentation requir:ments, including iaspectica reports, the " White Ecok,"
Public Cocument Rocas and the response requirements for identified deviaticas and unresolved items.
2.
Method of Accomplishment The preceding objectives were accszplished by discussions during the meeting on May 2, 1979, as summarized in the following para-graphs:
Tne Vendor Inspection Dranch (VIB) organizatica and related a.
NRC and Inspection and Enforcement of fice (IEE) organizations were described and ideatified.
b.
The LCVIF function was described, including why it was estab-lished, the VIB cbj ectives, the implementation structure and the applicable program requirements related to Exide.
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The conduct of VIB inspections was described and how the VIB inspections are documented, including the inspection report; Vender responses to the Notice of Deviations; how proprietary information is handled; the Public Document Rcom; and the "'4hite Book."
d.
The purposes and scopes of VIB scheduled inspections at Exide's two (2) manufacturing facilities during the weeks of May 14 and 23, 1979.
3.
Findings a.
Exide canagement acknowledged the above discussions and Exide's obligations in the supply of safety-related equip-ment to the commercial nuclear industry, b.
Exide management discussed their organization, product lines, outlined their quality assurance program and how it is struc-tured, the Quality Assurance Manual, and tests of their safety-related batteries, battery racks and other items related to batteries.
c.
Exide management stated that two (2) additional isolation bolts had been or will be installed in safety-related battery racks (Class IE) to isolate, in two (2) cell increments, the build up of horizontal momentum in a series of battery cells in each battery rack step during a postulated seismic event.
They further stated that this two (2) bolt isolation bar is not required for structural integrity, but only for the isolation of mcmentum and that the structural integrity will not be af fected by this addition to the Class IE battery racks.
d.
Exide canagement discussed a test program that had been completed at the '-yle Labcratory facilities at Huntsville, Alabama, during the week of February 26, 1979.
Yhey offered to show the film taken during the tests to document simulated seiscic testing of a battery system.
Note: On May 3,1979, the inspectors reviewed this documentary film on simulated seismic testing of a multi-celled battery under load.
The film showed in detail various simulated seismic testing on a two (2) dimensional computer operated shaker table. After completing the first series of testing, the batteries were turned 90 degrees on the shaker table and the testing sequence repeated.
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9 Records indicate that all tests were conducted with the test multi-celled battery under a load condition.
The com-poter operated shaker table was operated under random con-ditions to more closely simulate seismic movements than can be ;imulated by a sinusoidal method of testing.
A complete series of seismic tests were performed on the mi.lti-celled battery.
Testing was conducted at various speeds and ampli-tudes with a miximum amplitude of 10 times gravity (10g).
The records and film indicate that the multi-celled battery functioned as designed under the various test conditions.
C.
Organization 1.
Objectives The objectives of this area of the inspection were to verify that:
Autho_ity and duties of persons and organizations performing a.
activ; ties affecting safety-related functions had been clearly established and delineated in writing:
b.
Performers of the quality assurance functions had suf ficient authority and freedom to:
(1)
Identify quality problems.
(2)
Initiate, recommend and/or provide solutions to identi-fied problems, and (3) Verify implementation of sclutions.
The individuals respcasible for assuring effective executisn c.
of any portica of the quality assurance program had independ-ence f rom these directly responsible for performing :he specific activity 2.
Methods of Accomplishment The preceding objectives were acccmplished by Review cf the folicwing custcmer orders and attendant docu-a.
ments to verify that organization requirements had been invoked:
(1) PO Number KY-16948, dated July 3, 1973.
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10 (2)
PO Number KY-19260, dated December 5,1978.
(3) PO Number KY-20922, dated March 21, 1979.
(4)
PO Number KY-2755, dated April 13, 1979.
b.
Review of Exide Industrial Battery Division (Exide) Quality Assurance Manual, Section 1, Revision 8, dated January 27, 1979.
c.
Review of Exide Quality Assurance Manual, Section 6, Revision 8, dated January 27, 1979.
d.
Review of Exide Organizational Charts.
Review of Quality Control Procedure, Administrative, dated e.
August 1, 1977.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
D.
Procurement Document Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Procedures had been prepared and approved by Exide which prescribed a system for procurement document control that is consistent with NRC rules and regulations and Exide's commitments to custo:ers as established in the Exide QA Manual and related documents.
b.
The procurement dccument control procedures are properly and effectively implemented by Exide.
2.
Method of Accceplishment The objectives of this area of the inspection were accomplished by:
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11 a.
Review of Exide Quality Assurance Manual, Section 4, Revision 8, dated January 27, 1979.
b.
Review of Approved Vendor List (thirty (30) vendors on current list) dated January 1, 1979.
c.
Review of the following Purchase Orders (PO):
PO Number Date of P_j Items covered by PO KY-16948 July 3, 1978 "F" Line batteries KY-19260 December 5,19 73 Part S2374 of "C" Line batteries KY-20922 March 21, 1979 Separator MAX Part 82302 H0-2894 April 23, 1979 Trays, No. 61046 with covers, and change order related to change in number of trays d.
Review of Quality Control Procedure 30.8, " Vendor QC Seisaic Racks", dated August 1, 1977. This procedure delineates controls that apply to seismic racks requirements to meet Exide and/or customer requirements.
Review of Quality Control Procedure 30.9, " Seismic Rack e.
Welding Requirements and Welder Qualifications", dated November 1, 197S.
The purpose of this procedure is to establish welding requirements and welder operator qualifi-cations for fabrication of battery racks.
f.
Review of Quality Audit performed at the Kim Manufacturing Company, Dowingtown, Peansylvania en June 1,
- 1977, g.
Review cf materials test date for first quarter 1979 (Amerace).
h.
Review of Material Test Reports (MTR) file for Amerace Corporation for 1979 (January 1 through April 30, 1979).
i.
Review of Quality Audit for Mack Molding, dated August 15, 1979.
j.
Review of MTR file for Mack Molding for 1979 (January 1 through April 30, 1979).
b'.
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Review of Vendor Quality Program Sursey (St. Joe Minerals Corporation) dated May 26, 1976.
1.
Discussions with cogaizant management personnel on QA functions related to procurement document control.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
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