ML19254D415
| ML19254D415 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1979 |
| From: | Kelley W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19254D405 | List: |
| References | |
| REF-QA-99900075 99900075-79-1, NUDOCS 7910250467 | |
| Download: ML19254D415 (13) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900075/79-01 Company:
MCC-Pacific Valves 3201 Walnut Street Long Beach, California 90007 Inspecni::n Conducted: July 16-17, 1979 Iaspect::rs:
UldyfY 07 Cdf04f99 Wm. D. Kelley, Contractor Inspector Date ComponentsSection I Vendor Inspection Branch w
f wa M'al awu D. E. Whitesell, Chief ~
Date ComponentsSection I Vendor Inspection Branch Approved by:
A4I/r
/)4'/48 f
D. E. Whitesell, Chief Date ComponentsSection I
- Ven' dor Inspection Branch Summary Inspection on July 16-17, 1979 (99900075/79-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, and applicable codes and standards including, design and document control - design input, inspection and test, audits, and nonconformance and corrective action. Also performed general review of vendors activities and review of previous findings.
The inspection involved twenty-four (24) inspector-hour on site by two (2) NRC inspectors.
Results-In the six (6) areas inspected, no deviations or unresolved items were identified in four (4) areas. The following were identified in the remaining two (2) areas.
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2 Deviations: Design and Document Control - Design Input (Section 1, paragraph A.3.a) - Organization changes had been made and ASME accepted Quality Assurance Manual act revised and submitted to the AIA specialist for acceptance.
Previcusly Identified Items (Section 1, paragraph C.2) - The stated corrective action in MCC-PV's letter of December 21, 1978, had not been implemented.
Unresolted Items: None.
1209 255
3 DetailsSection I (Prepared by Wm. D. Kelley)
A.
Perscns Contacted MCC-Pacific Valves (MCC-PV)
- R. L. Audibent, Manager of Quality Assurance
- J. P. Fleming, Quality Assurance Engineer
- F. W. Heckenkamp, Vice President of Engineering
- N. Kedner, Quality Assurance Engineer
- B. J. Rankin, President
- J. I. Rosen, Supervisor Quality Assurance Engineering
- Denotes those persons who attended the Exit Interview (See paragraph G.).
B.
General Review of Vendor's Activities 1.
The ASME issued the following Certificates of Authorization to MCC-PV to use th~eir symbol:
Certification No.
Syrnbol Product N-1202 N
Class 1, 2, and 3 valves N-1203 NPT Class 1, 2, 'ad 3 valve parts anH appurtenances These certificates expire on August 4, 1981.
2.
The authorized inspection agency is the State of California, Division of Industrial Safety. The authorized nuclear inspector is an itinerant inspector.
3.
MCC-PV's coatribution to the nuclear industry represents approxi-mately four and one half percent (4 1/2%) of its total workload.
4.
The name of the company is now MCC-Pacific Valves.
5.
The following organizational changes have been made:
Three new positions, executive vice president, vice president of a.
engineering and supervisor of vendor quality control,. have been created and present personnel assigned to these positions.
b.
The positions of president and manager of quality assurance have been filled by personnel outside of MCC-PV.
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4 c.
The manager of quality assurance now reports to the vice president of engineering.
6.
MCC-PV has the design and manufacturing capabilities to produce gate, globe, and check valves from 1 1/2 inches to 30 inches in si: e and ANSI 1500 to 25000 pressure classes.
C.
Previcusly Identified Items 1.
(Closed) Deviation (Report No. 78-02, Item A.):
Contrary to Criterion V of Appendix B to 10 CFR 50, paragraph NCA-4134.5 of Section III of the ASME Code, and paragraph 12.3.1 of the ASME accepted Quality Assurance Manual Project Engineering did not provide an index of the documents retained in their respective department for any purchase order.
The iispector verified the Project Eng.: ering had provided an index of the documents retained in their respective department for any purchase order.
2.
(Closed) Deviation (Report No. 78-02, Item B.):
Contrary to Criterion V of Appendix B to 10 CFR 50, paragraph NCA-4134.5 of Section III of the ASME Code, and paragraphs 4.6.1 and 4.6.3 of the ASME, the training records for welders, nondestructive testing personnel, and inspectors, show that training was not held on a quarterly basis.
During the current inspection, the inspector verified that the training sessions of welders, condestructive testing personnel and inspectors were held at a greater frequency than quarterly; -
however, the stated corrective action as committed in MCC-PV's letter of December 21, 1978, had not been implemented in that.
Deviation, See Notice of Deviation Item B.
3.
(Closed) Deviation (Report No. 78-02, Item C.):
Contrary to Criter' ion XII of Appendix B to 10 CFR 50, paragraph NCA 4134.12(c) of Section III to the ASME Code, and Sections 4.4.4.3.14, 15, and 16 of the ASME accepted Quality Assurance Manual the QC inspectors were not recording on the back of the PW0s for the part inspected, the identification of the tools or gages used to verif, the accept-ability of the werk.
Reviewed WO #H7030-01 for Part No. 4560-10 WE-Spec SR, to verify that it provided traceability to the inspection equipment used to verify that the part dimensions were within the acceptance tolerance.
It was verified that the WO identified the Dimensional Inspection Work Sheet which identified each measuring equipment used to verify the acceptability of the part, by serial number.
It also provided the calibration status for each instrument used.
f.}.C) }.h-.-.
5 4.
(Closed) Unresolved Item (Report No. 78-02): MCC-PV was inconsistent in their record storage requirements in that the records ia the QA Lepartment were maintained in file cabinets with one L ur fire ratings and records in Project Engineering are maintained in file cabinets with no fire rating.
The inspector verified that the Project Engineering records have been refiled in fire resistant file cabinents.
5.
(Closed) Unresolved Item (Report No. 78-02): MCC-PV's present method of documenting the QAE's review of the SJI by using an internal memorandum does not prevent the issuance of SJIs for production, without the QAE's comments being resolved.
The inspector verified all of the QAE's comments are resolved in the design review meetings prior to the issuance of the SJIs.
D.
Design and Document Control - Design Input 1.
Objectives The objectives of this area of the inspection were to verify that:
Procedures had been prepared and approved by the vendor to a.
prescribe a system for the control of the design inputs which are consistent with NhC rules and regulations and his commitments in the ASME accepted Quality Assurance Manual.
b.I The design input procedures are properly and effectively implemented.
2.
Method of Accomplishment The objective of this area of the inspection was accomplished by:
Review of the ASME accepted Quality Assurance Manual, a.
Revision 0, dated September 21, 1978; (1) Section 6.0, Order Planning, and (2) Section 7.0, Design Control
~
to verify the vendor had established procedures to prescribe a system for control of design input.
b.
Review the following procedures; (1) EDS-1, Revision 2, Preparation and Use, Preparation and Use of Engineering Change - Transmittal Notice, 1209 258
6 (2) EDS-3, Revision 4, Distribut'en and Control of Nuclear Detail Drawings and (3) EDS-4, Revision 6, Preparation and Use of Shop Job Instructions to verify that they had been prepared by the designated authority, approved by management, and reviewed by QA.
c.
Review the following documents; (1) Shop Job Instructions, (2) Custcmer Design Specification and Purchase Order, and (3) Minutes of the pre-release meeting; to verify they had been properly and effectively implemented, the design input is correct and had been verified and documented.
d.
Review of Paragraph 1.2; cud Figure 1-1 in Section 1 of the Vendor's ASME accepted Quality Assurance Manual to verify that the QA Manual had been revised to reflect the changes in the organizational structure of MCC-PV, and the revision documented in accordance with the QA Manual commitments.
- e.. Interviews with personnel to verify that they are knowledgeable 8
in the procedures applicable to design input.
3.
Findings a.
Deviation See Enclosure Notice of Deviation, Item A.
b.
Unresolved Items Within this area of the inspection, no unresolved items were identified.
E.
Audits (Internal Management) 1.
Objectives The objectives of this area of the inspectica were to verify that:
Procedures had been prepared ant approved by the vendor to a.
prescribe a system for auditing (Internal Management) which is consistent with NRC rules and regulation, and the vendor's commitments in the ASME accepted Quality Assurance Program.
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7 b.
The audit procedures are being properly and effectively implemented by the vendor.
2.
Method of Accccolishment The objectives of this area of the inspection were accomplished by:
Review of the ASME accepted Quality Assurance Manual, Revision 0, a.
dated June 21, 1978; (1) Section 4.0, Quality Assurance, and (2) Section 4.0, Procurement Control to verify that procedures had been established to prescribe a system for auditing, which is consistent with NRC regulations.
b.
Review of QAS-5, Revision 4, Quality Assurance Standard frr Internal Audits to verify that it had been prepared by the designated authority, approved by management, and reviewed by QA.
Review of the documents listed in paragraphs a and b to verify c.
that they identify the organizations responsible for auditing and their responsibilities; establishe; audit personnel qualifications and training, and that the audits are performed by qualified personnel. Also, to verify that the essential elements of the audit system is established.
d.'
Review of the audit schedules to assure that the audits of,
quality activities during design, procurement and manufacture are planned, documented, and conducted in the prescribed manner, and assures coverage of all aspects of the QA Program.
Review of selective audit reports to verify that they include e.
provisions for written plans, raam selection, team orientation, audit notifications, pre-audit _ nferences, audit performances, and post-audit conferences.
f.
Review of selective audit reports to verify tflat they are properly distributed to managment and the audited organi-zation; and that follow-up audits to verify corrective action is required.
g.
Review of selective internal and external audit reports to verify that the applicable procedures were available to the audit team personnel, and that the audit procedures were properly and effectively implemented.
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8 3.
Findings a.
The inspector verified that:
(1) Procedure had been prepared and approved by the vendor which prescribes a system for auditing consistent with NRC rules and regulation, ASME Code and contract require-meats, and the vendor's commitments.
(2) The audit procedures are being properly and effectively implemented by the vendor.
b.
Within this area of the inspection, no deviation or unresslved item were identified.
F.
Review of IE Circular No. 78-15 with MCC-FV 1.
Objective The objective of this area of the inspection was to review the design of the vendor's check valves and evaluate their ability tc clcse if installed in a vertical position rather than the normal horizontal position.
2.
Method of Accomplishment a.
Review of NRC IE Circular No. 78-15.
b.
Review of NRC IE's letter dated December 28, 1978, H. D. Thornburg to MCC-Pacific Valves.
c.
Review of MCC-Pacific Valves' letter dated November 30, 1978, to NRC.
d.
Review of check valve design drawing, e.
Interviews with engineering personnel.
3.
Findings The IE Circular No. 78-15 limited its concern to only tilting disc check valves installed in vertical pipeline rather than.a horizontal pipeline.
It should be noted that the circular did not address other check valve designs such as swing check and lift check, nor did it address the direction of normal flow when the check valve is to be installed in the veritical pipeline.
The MCC-PV swing check valve designs reviewed by the inspe'ctor have stops to prevent the disc of a valve installed in a veritical pipeline from hanging in the barrel of the valve body and out of the flow steam; however, MCC-PV stated that the normal flow must be upward for their valve to function properly.
1209 26i
9 Certain manufactures have a..ine of check valves that are specif-ically designed for vertical pipeline installations with the flow upward.
It is the responsibility of the piping system design engineer to review his system installation and include in his valves design specifications those special installation parameters that affect the operability of check valves, or speciality. type flow control devices.
~'ithin this area of the inspection, no deviations or unresolved items w
were noted.
G.
Enit Interview At the conclusion of the inspection on July 17, 1979, the inspector met with the company's management, identified in paragraph A, for the purpose of Laforming them as to the results of the inspection. During this meeting each identified deviation was discussed and the evidence which supported the findings were identified.
The company's management acknowledged the findings and supporting evidence as being understood, but had no additional comment.s.
}20h
10 DetailsSection II (Prepared by D. E. Whitesell)
A.
Persons Contacted J. Flemicg S. Sanard F. Hernandez B.
Inspection and Test 1.
Objectives The objectives of this area of the inspection were to ascertain whether the vendor had developed and implemented detailed written procedures for performing the various inspections and tests required by the code, and contract documents. Also to verify whether the inspections and tests were being performed by properly qualified personnel, in a cordance with the procedures.
2.
Method of Accomplishment The objectives were accomplished by:
a.
Review of DS number FLO-2998-111C, dated October 19, 1973, for 2 1/2" and larger Steel valves. Also Revision 1, dated Februa ry 26, 1974; Revision 2, dated October 10, 1974; and,.
Revision 3 dated February 27, 1976, to verify whether inspections and tests over and above the code requirements had been specified.
b.
Review of Sections 4.3.4, "The NDE Specialist"; 4.3.5 "The Inspection Foreman"; and 4.3.8, "The Gage Control Techician" in the QA Manual, to ascertain whether the QA Program prescribes a system of inspection and test activities to support the controlled manufacturing process to ensure compliance with the ASME code and contract requirements. Also to determine whether the duties and responsibilities of the personnel performing these activities were established and adequately detailed in writing.
c.
Review of precedure numbers P1728, Revision 8, dated November 3, 1977; " Wall Thickness Measurements"; P1743, Revision 4, dated November 8, 1976; " Liquid Penetrant Examination"; P1745, Revision 6, dated October 31, 1977; Hydrostatic Test for Class 1, 2, and 3,Section III Valves; P1746, Revision 4, dated October 24, 1977; " Radiographic Testing"; to verify whether the detailed written procedures
))_00
11 provided for appropriate acceptance standards and, if required, had been qualified. Also to verify that the procedures were in cocpliance with the ASME code requirements, and had been reviewed and approved by the customer.
d.
Review of QAS-6 " Training" for the qualification of Level I, and II inspectors.
Review of QAS-11 "Use and Control of Inspector's Stamps."
e.
f.
Observation of inspection and test activities being performed on the shop floor and discussions with the individuals responsible for the work to ascertain whether the procedures are available to them and whether they are knowledgeable concerning the procedure requirements.
3.
Fjndings No deviations or unresolved items were identified.
C.
Nonconformance and Correttive Action 1.
Objectives The objectives of this area of the inspection were to verify that:
Procedures had been developed and approved by the vendor that a.
- prescribes a system for control of nonconformances and assuring effective corrective action in a manner consistent _
with NRC rules and regulatica, ASME Code requirements, and the vendor's commitments in the ASME a ccepted Quality Assurance Program.
b.
The nonconformance and corrective action procedures are properly and effectively implmented by the vendor.
2.
Method of Accomolisneent The objectives of this area of the inspection was accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual; (1) Section
.1, "Nonconformance Processing,"
(2) Section 4.4.2, " Disposition of Discrepant Conditions", and (3) Section 4.4.3, " Corrective Action"
)h
12 to verify that the vendor had established procedures that prescribed a system for identifying and reporting nonconformances and requires corrective action, in a manner consistent with the NRC regulations, ASME Code, and contract requirements.
b.
Review of the following documents; (1) Review of Section 4.4.1.3, Tagging and Hold Area for discrepant items, and (2) Production Wor'x Order (PWO) No. PWO 040-R01, dated April 26, 1978, Part-Disc G15-32-W-SR JN-6N0083N, Inspection stamp in Reject dated July 12, 1978 to verify the system of nonconformance provides identification of inspection points, personnel responsible for identification, inspection method, acceptance criteria, personnel responsible for nonconformance and for resolution, segregation of item, and distribution of report.
c.
Review of the following documents; (1) Discrepant Material Notice (DMN) No. 0969 for above PWO No. PW 0040-R01, and (2) Rework Order (RWO) No. 2085-01 for the above DMN No. 0969 to verify that the system for corrective action has been
/ implemented and is consistent with the Vendor's commitments Also to verify that the receipt and analysis of nonconformance reports,the recommended corrective action,and follow-up, to assure corrective action is effective; and verify that the corrective action procedures provide for management participation in nonconformance report and corrective action review.
d.
Review of six (6) nonconformance reports to verify that the nonconformance and corrective action procedures were properly implemented in that the assigned responsibilities were carried out, the identification and reporting of nonconformances and the evaluation and enacting of the corrective action was timely and effective, nonconforming items were properly dispositimed.
e.
Interviews with personnel to verify they were aware of and had access to the nonconformance and corrective action proce-dures.
g09
13 3.
Findings a.
The inspector verified that:
(1) Procedures had been developed and approved by the vendor that prescribed a system for control of nonconformances and assured effective corrective action in a manner consistent with NRC rules and regulations, ASME Code requirements, and the vendor's connitments in the ASME accepted Quality Assurance Program.
(2) The nonconformance and corrective action procedures were properly and effectively implemented by the vendor.
b.
No deviations or unresolved items were identified.
D.
10 CFR 21 Inspection 1.
Objectives The objectives of this area of the inspection we e to ascertain whether the Vendor had been contractually obligated to comply with the requirements of 10 CFR 21, and whether Section 206 of Public Law 93-438 was posted as prescribed.
2.
Method of Accomplishment The foregoing objectives were accomplished by:
a.
Discussions with the cognizant personnel.
b.
Observation of the bulletin available to MCC-PV employees.
c.
Review.f Procedure No. OP0004, Revision 0, dated February 7, 1978, which establishes the detailed instructions concerning how the employees are to document their reports of any significant deviations.
3.
Finiings The insp'.ctor was informed that MCC-PV is obligated by its nuclear contracts to develop and implement, _o;edures for reporting significant defects.
It was observed that Section 10b of Public Law 93-438 is posted and procedure for reporting and documenting reports is available to the MCC-PV employees.
MCC-PV stated that it relies on its nuclear customer to ev'aluate the safety significance of any defect identified.
e 1209 266