ML19260D026
| ML19260D026 | |
| Person / Time | |
|---|---|
| Issue date: | 12/17/1979 |
| From: | Hunter V, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19260D017 | List: |
| References | |
| REF-QA-99900053 99900053-79-2, NUDOCS 8002070269 | |
| Download: ML19260D026 (8) | |
Text
U. S. NUCI. EAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCE 1NT REGION IV Report Nc. 99900053/79-02 Program No. 51300 Company:
Anchor / Darling Valve Co.
701 First Street Williamsport, Pennsylvania 17701 Inspection conducted: October 30 to November 1, 1979
/*.y Okk,TW,lC,
/
Inspecto
):2./7 N V. H. Hu er, Contractor Inspector Date Componen.sSection I Vendor Inspection Branch f.
Approved by N /'
ei _.- T
/2 /9-fV D. E. k'hitesell, Chief Date ComponentsSection I Vendor Inspection Branch Summarv Inspection on October 30, to Novemhe.r 1, 1979 (99900053/79-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including management meeting, QA program review, audit control, ANI interface, and follow-up of reported deficiencies.
The inspection involved twenty-two (22) inspector hours on site.
Results:
In the five (5) areas inspected, no apparent deviations or unresolved items were identified in four (4) areas. One (1) apparent deviation was identified in the remaining area.
Deviation: Audit control. Cor irsry to Criterion XVIII of Appendix B to 10 CFR 50 and procedure MQCS-1, corrective actions were not taken within the required time frame.
(See Notice of Deviation.)
1938 017 80 0 2 07 0 S b f
2 DETAILS SECTION A.
Principal Persons Contacted Anchor / Darling Valve (ADV)
- D. R. Wiborny, Plant Manager
- G. W. Knieser, Quality Assurance Manager L. D. Snyder, NDE Level III and QA Engineer G. M. Simeon, Design Coordinator Commercial Union Assurance Comoanies
- R. E. Montgomery, Autho. ' zed Nuclear Inspector (ANI)
- Denotes those who attendd exit interview.
3.
Management Meeting An initial meeting was held with ADV management where the inspector explained the internal policy of the Vendor Inspection Branch that provides for periodic turn-over of principal inspectors. Also, explained were phase I, II, and III type inspections and that this visit initiated phase III of our program.
ADV management provided the inspector with, or information relative to, the following:
1.
Copy of the ASME accepted QA Manual.
2.
Current organization chart.
3.
Current list of on-going projects.
4.
Functional lines of communications.
5.
Approved Vendor List.
C.
QA Program Review 1.
Objectives The objectives of this areas of the inspection were to verify that the QA program changes have been documented in writing, and have been 1938 018
3 implemenc.ed to control quality related activities. Also to ascertain that the program provides for the followin;:
a.
Management's policy statements concerning QA.
b.
The QA organization being structured to achieve organizational independence and freedom to:
(1) Identify quality problems.
(2)
Initiate appropriate resolutions.
(3) Verify corrective actions.
c.
Provides the QA staff with the authority, aod access to a level of management, that ensures effective implementation of the QA program elements, and to enforce positive and timely corrective action.
d.
The duties, responsibiltcies, and the authority of the QA staff are clearly delineated in writing.
Detailed written procedures, properly reviewed and approved, e.
are available to control quality activities.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the current ASME accepted QA Manual.
b.
Review of representative copies of the QA Manual.
c.
Review of QA audits of the QA Manual.
d.
Interviews with vendor personnel.
3.
Inspection Findings Within those areas inspected there were no deviations or unresolved items identified.
D.
ANI (Authorized Nuclear Inspector) Interface 1.
Objectives The objectives of this inspection were to verify that:
The ANI has direct contact with the cognizant plant QA/QC a.
representative.
1938 019
4 b.
The ANI has free access to all parts of the plant concerned sith supply or manufacture of ASME Code work.
c.
All applicable documents are available to the ANI for review.
d.
The ANI identifies and signs off on witness hold points or process control documents and witnesses the qualification of special NDE procedures.
e.
The ANI maintains a log of activities reviewed and/or witnessed.
2.
Method of Accomolishment The preceding objectives were accomplished by:
Review of revision 15 of the ASME accepted QA Manual.
a.
b.
Discussion with the ANI.
c.
Review of the ANI log book of inspection activities.
3.
Findings The ANI is a resident inspector who is assigned to this shop a.
on a full time basis.
b.
All necessary documents are made available to the ANI. The ANI has accest to all plant facilities related to his work.
Review of the.CI inspection log established it was consist-c.
ently maintained.
d.
Within this area of the inspection, no deviations from commitment or unresolved items were identified.
E.
Audit Control 1.
Objectives The objectives of this area of the inspection were to verify that procedures had been prepared and approved by the vendor that pre-scribed a system for auditing which is consistent with the commit-ments of the ASME accepted Quality Assurance Manual. Also, verify that these audit procedures were being properly and effectively implemented by the vendor.
1938 020
5 2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
Review of the ASME accepted Quality Assurance Manual, Section a.
4.0, titled " Quality Control" to verify that procedures had been established to prescribe a system for auditing.
b.
Review of the following documents:
(1) Current audit check list (2) Current audit schedule (3) Audit personnel qualifications to verify that they had been prepared by the designated authority, approved by management, and reviewed by quality assurance.
Review of procedure MQCS-1, revision P, titled " Quality Assurance c.
Standard for Internal Audits" to verify that they identify the organizations responsible for auditing and their responsibility; establish audit personnel qualifications and training and the audits are performed by these personnel; and establish the essential elements of the audits system.
d.
Review of selective audit reports to verify that they identify the written plan, team selection, team orientation, audit notification, pre-audit conference, audit performance, and post-audit conference.
Review of randomly selected audit reports to verify that the e.
distribution to management, and the audited organization, and follow-up regarding corrective action had been accomplished.
f.
Review of 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 inplemented.
3.
Findings a.
Deviation See Notice of Deviation.
1938 021
6 b.
Urresolved Items None were identified.
F.
Follow-up of Reported Deficiencies 1.
Background Data On June 14, 1979, the NAMCO Controls Corporation filed a report as required by 10 CFR 21.
This report stated that NAMCO had manufactured and shipped limit switches with less than the required QA controls in effect.
Further, the report listed those valve companies in receipt of the affected limit switches, one of which was the Anchor / Darling Valve Company of Williamsport, Pennsylvania.
2.
Objectives The objectives of this inspection were to:
Det rmine the quality requirements imposed on Anchor / Darling a.
(A/t by the utility customer.
b.
Detersine the quality requirements imposed on NAMCO by A/D.
c.
Determine the status of the affected limit switches relative to quality requirements.
3.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Review of South Carolina Electric and Gas Co. (SCEG) contract numbers SN-10109-SR and SN-10209-SR with A/D for various valves and associated equipment.
b.
Review of SCEG General Specification Number SP-515-4461-00.
c.
Review of SCEG Design Specification Number DSP-515A-4461-00 (for Code requirements).
d.
Review of SCEG QA Specification Number SP-701-4461-00.
e.
Review of A/D document packages for job numbers E-6188 and E-6252 for valves and associated equipment (including limit switches) being supplied to the Virgil C. Summer Nuclear projects.
f.
Review of A/D Approved Vendor List.
1938 022
7 g.
Review of Gilbert Associates, Inc., Bill of Materials dated March 22, 1978.
4.
Inspection Findings a.
In the review of the foregoing documents it was observed that item 2.07.4.3 in SP515-4461-00 and item 1.13.2 in SP 701-4461-00 both state in part, "The limit switches shall be National Acme, Snaplock, series SL or equal." The QA specification SP 701-4461-00 also imposed IEEE Standards 344 and 382.
It was also noted that the three SCEG specifications identified were reviewed and approved by Gilbert Associates, Inc., (GAI) on October 12, 1978, and issued to A/D on December 31, 1974.
PO No. SN 101-09-SR was revised by GAI Bill of Material, dated March 22, 1978.
The revision included a change to be made in item 2.07.4.3 of SP 515-4461-00 to read:
"The limit switches shall be National Acme, Snaplock, series EA 170 or EA 180, or equal." By specifying a specific make, type, and series, it appears that SCEG is the buyer (purchasing through A/D) and has the responsibility for qualifying the single source supplier identified in its P0 to A/D.
This indication is rein-forced by the fact that GAI as agent for SCEG, apparently in compliance with Criterion VII of Appendix B to 10 CFR 50, audited the QA program implemented by NAMCO, to control the manufacture of the specified limit switches. As a result of this audit, GAI, as SCEG's agent, required NAMCO to implement corrective action by developing procedure No. QA-2-101 dated February 7, 1979, " Addenda to Quality Assurance Manual."
A copy of the approved QA procedure No. QA-2-101 was transmitted by GAI to A/D by letter dated February 15, 1979, identified as No. CGGV-2354-QA, and referencing SCEG PO Nos. SN-10109-SR and SN-1029-SR. The letter also obligates A/D to include a reference to the addenda in any purchase orders which A/D places with NAMCO for safety related limit switches for the V. C. Summer Project. GAI's reference to limit switches as being " safety relatei," triggered a series of correspondence and phone discussions between A/D, SCEG, and GAI concerning this matter.
The inspector was informed by A/D, that during a telephone contact with GAI, A/D learned that the limit switches would be connected into, and become a component of, a safety related electric control circuit. This raises the question as to whether the buyers of nuclear components and equipment, are furnishing the suppliers with sufficient information ccacerning the intended service, to enable the supplier to assure and document that the required quality of the item has been achieved.
1938 023
8 b.
It was A/D's position that they had met their contractual obligations due to the following:
(1) The intended use of the limit switches for indicating "Close-open" status of manually operated valves (as inter-preted from the SCEG design criteria) is functionally inde-pendent of the fail or non-fail mode of the valve.
(2) The buyer limited A/D to a single source and specific type and quality of limit switches to be used to indicate the position of the valves included in his purchase orden (a) This implied that the buyer is exercising his responsibility for product acceptance before the fact, and has prejudged that the type and quality of the product will be satisfactory for its intended service.
(b) The requirement that the limit switches were to be qualified in compliance with IEEE 342 and 382, was included in the A/D PO to NAMCO, as required by the quality specification number SP 701-4461-00; which also obligated A/D to a QA program commensurate with American Nuclear Society (ANS) Standard N18.2 which has never been approved by NRC as meeting the requirements of Appendix 3 to 10 CFR 50.
All limit switches that were manufactured and shipped with marginal c.
QA program requirements have been returned to NAMCO. All further shipments of limit switches will be manufactured under QA programs consistent with Appendix B to 10 CFR 50.
d.
This item appears to be limited to the Virgil C Summer facility only and not generic to other facilities.
e.
No apparent deviations or unresolved items were identified.
H.
Exit Interview The inspector met with management representatives denoted in paragraph A above at the coaclusion of the inspection on November 1, 1979.
The inspector summarized the scope and findings identified during the in-spection. Management representatives acknowledged the inspector's comments regarding the scope and findings as presented.
1938 024