ML19274E965
| ML19274E965 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/1979 |
| From: | Sutton J, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19274E960 | List: |
| References | |
| REF-QA-99900356 99900356-79-1, NUDOCS 7906070026 | |
| Download: ML19274E965 (12) | |
Text
,
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900356/79-01 Program No. 51400 Company:
Burndy Corporation Husky Products Division 7405 Industrial Road Florence, Kentucky 41042 Inspection at:
Florence, Kentucky Inspection Conducted:
February 12-15, 1979 Inspector:
.h 8"7-27
- y. W.~ Stitton, Contractor Inspector, Vendor Date Inspection Branch Approved b.
3-Fff D. Ohitesell, ComponentsSection I, Vendor Date Inspection Branch Summary Inspection on February 12-15, 1979 Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, and applicable codes and standards; including initial management meeting, vendors activities, QA Program Review, manufacturing process control, special process control, training, and audit.
The inspection invcived twenty-eight (28) inspector-hours on site.
Results:
In the seven (7) areas inspected, no apparent deviations or unresolved items were identified in three (3) areas. The following were identified in the remaining four (4) areas.
Deviations: Organization:
(1) duties and responsibilities of personnel not clearly delineated; (2) management policy statement not included in QA Program (Enclosure, Item A). Special processes: welding procedure does not establish welding parameters to be used for joining materials under inch thickness. (Enclosure, Item B.)
79060700%
Unresolved Items:
Process control - issuance and use of route cards (Details, Section E.3.b).
Special processes - welding procedure issuance not designated (Details, Section F.3.b).
Training - Indoctrination /
Training of employees not documented (Details, Section G 3.b).
ee
., - -.. - ~, -. - - -. _ _ _ _. _ _
. ~..
Details A.
Persons Contacted
- F. L. Banta, Engineering, R&D Manager
- C. F. Duncan, Quality Assurance Manager
- W. Muellen, Production Manager R. Pratt, Industrial Engineer
- D. J. Ring, President and General Manager
- Denotes those present at the Exit Interview.
B.
Initial Management Meeting 1.
Objectives The objectives of this meeting were as follows:
a.
To meet with the Burndy/ Husky Products Division management and those persons responsible for the administration of the Company's QA Program, and to establish channels of comunica-tion.
b.
To determine the extent of the company's involvement in the nuclear industry.
c.
To explain NRC direct inspection program, including the VIB organization, VIB inspection methods, and documentation.
2.
Method of Accomplishment The preceding objectives were accomplished by a meeting on February 12, 1979.
The following is a summary of the meeting:
a.
The VIB organization was described and its relationship to NRC Region IV and the NRC Headquarters component of the Office of Inspection and Enforcement.
b.
The VIB was described i mluding the reasons for its estab-lishment, its objectives, its implementation structure, and the more significant program changes as they may impact on the vendor inspection program.
c.
The conduct of VIB inspections was described and how our inspections are documented including the report, responses
to reports, how proprietary information is handled, the Public Document Room, and the White Book.
d.
The company's contribution to the nuclear industry was discussed including current and projected activity.
3.
Results a.
The inspector was informed that the Husky Products Division of the Burndy Corporation primarily is a designer / fabricator /
manufacturer of electric cable support systems. The companys contribution to the nuclear industry is estimated to be 30%
of its total business, b.
Cable support systems are designed and fa.bricated to the following requirements:
(1) National Electrical Manufacturer Association Standards (NEMA) (issue designated) Cable Tray Systems.
(2) National Electrical Code (NEC) 1975; Article 318 - continuous rigid cable supports, Article 365 - cable bus, and Article 710 - over 600 volts general.
(3)
Individual customer contracts impose the governing Codes and standards, such as 10 CFR 50, Appendix B, ANSI Standards, IEEE, and AWS Codes, and ASME Section IX for welding qualification requirements.
(4) Currently there are ten (10) nuclear contracts in house for design and fabrication of electrical support systems.
c.
The inspector was conducted on a tour of the facility.
C.
Review of Vendors Activities 1.
Objectives a.
The objectives of this area on the inspection was to review the vendors activities to assess their impact of future IE inspections.
. b.
Review of fabrication / manufacturing techniques and equip-ment.
c.
Review of current work loads.
2.
Method of Accomplishment The foregoing objectives were accomplished by observing th'e manufacturing / fabrication processes implemented by the vendor.
3.
Results a.
The vendor operates a full production line, where raw materials, such as sheet steel and aluminum, is received in coils of varing widths from approved material warehouses.
It is then cut, punched, bent, and welded into required shapes and forms, as required by the contract or specifica-tion. Some of the steel is received pre-galvanized. Hot dip galvanizing is perfomed by the company, after fabrica-tion, if required by the contract / specification. 85% of all the welding is performed by automatic spot welding (Resistance). The balance of the welding is performed using the semi automatic MIG-TIG processes. The majority of the welding is the joining of 14-16-18-20 gage materials.
Spot welding operations are not code related, and automatic welding machine settings are as recommended by the machine manufacturer.
All welders are, or will be, qualified to the ASME Code Section IX requirements.
Inspection of products is accomplished only by visual methods.
The vendor has generated a visual weld inspection procedure and acceptance criteria, and instruction for the QC inspectors use. The vendor operates on an incentive work program geared to production.
In-process inspections are identified on the route cards, and space is provided for the QC inspectors signature, date, and the results of his inspection.
Required QC records are collected and checked and shipped with the finished product.
b.
Future VIB inspections of this shop is recommended to be on a reactive or special need basis.
D.
QA Manual Review 1.
Objectives The objectives of this area of the inspection were to verify that the QA Program has been documented in writing, and has
. been implemented to control quality related activities consistent with regulatory, Code, and contract requirements. Also, to ascertain whether the program provides for the following:
a.
A management policy statement concerning QA.
b.
The QA organization structured to achieve organizational independence and freedom to:
(1)
Identify quality problems.
(2)
Initiate appropriate resolutions.
(3) Verify corrective actions.
c.
The QA staff has the authority, and access to a level of management that ensures effective implementation of the QA Program, and to enforce positive and timely corrective action.
d.
The duties, responsibilities, and the authority of the QA staff are clearly delineated in writing, e.
That detailed written procedures to control quality activities are properly reviewed, approved, and released for use.
2.
Method of Accomplishment The preceding objectives were accompli _shed by:
a.
Review of the Burndy/ Husky Quality Assurance Manual dated February 19, 1978, to verify '. hat it n.eets the requirements of 10 CFR 50, Appendix B, and other applicable Codes and standards, b.
Review of Section I and II of the QA Manual, in particular the organization structure, function and responsibilities, to verify that the QC organization has the independence and authority to identify QA problems and enforce corrective action.
c.
Review of Sections V, VIII, and XVIII of the QA Manual, to verify that detailed written procedures are reveiwed, approved, released, distributed, and used to control quality activities.
. d.
Review of Quality Assurance Procedures (QAP) 100, 100A, 101, and 102.
3.
Findings a.
Deviations See Enclosure, Item A.
b.
Unresolved Items None.
E.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that the vendor was controlling his manufacturing activities in accordance with the NRC regulation and contract requirements.
Also, to ascertain whether the controls were being properly implemented.
2.
Method of Accomplishment The foregoing objectives were accomplished as follows:
a.
"t /iew of the QA Manual Section V, VIII, X, XIII, and XIV, to verify that measures had been established for the use of process sheets, travelers, or equivalent, which describe in detail all fabrication, assembly, and inspection operations. -
It was verified that the vendor uses a computer print-out route card, which provides the specific instructions for each fabrication, assembly, and inspection operation.
It also provides space for the sign-off by the production and QC personnel.
b.
Review of the following QAP's:
(1) QAP-114A, First Piece Inspection.
(2) QAP-1148, In-process Inspection.
(3) QAP-115, Final Inspection.
(4) QAP-115A, Inspection Log.
. c.
Review of contracts and specifications for three (3) contracts presently in house and in process, contract Nos. 2015, 6151, and 3334.
d.
Review of the route cards and order Nos. 001124, No. 92, 615117, 615115, 648110, and 615116.
e.
Review of Drawings No. 59M-14-12-144-1T, SSM-24V090-24, and 24H45-211.
f.
Review of the Inspector's Log Book.
g.
Inspection of shipping and storage areas to verify the control of materials.
h.
Discussion with shop personnel.
3.
Findings a.
Deviation None.
b.
Unresolved Item Instructions for generation, use and issuance of shop route cards has not been documented.
Verbal instructions are presently being given. The computer is used to control the storage and issuance of shop route cards.
c.
General The vendor presently is reviewing, revising, and generating new quality control procedures, as needed to comply with the regulations and contract document requirements.
F.
Control of Special Processes, Welding Procedure Specifications Use and Control 1.
Objectives The objectives of this area of the inspection were to verify that welding procedure specifications used for production welding were controlled and used in accordance with the Burndy/ Husky QA Program and NRC and the contract designated Code requirements.
_9 2.
Method of Accomplihment The preceding objectives were accomplished by:
a.
Review of the QA Manual Section IX, revised January 15, 1975, titled " Control of Special Processes."
b.
Review of the following procedures, QAP 104 (December 11, 1978), Inspection of Resistance Spot Welding; QAP 104A (September 15,1975), Auto Spot Welding Inspection Require-ments; and QAP 107, Revision 3, Steel MIG Welding.
c.
Review of welder issuance record.
d.
Review of qualified welder list dated January 1,1979, and the system used to maintain qualifications and proficiencies.
e.
Review of engineering standard (ES) 001 effective February 28, 1979, titled " Welding Quality" (MIG &TIG).
f.
Review of the weld procedure qualifications and the welder's qualification records.
g.
Observation of weldin] activities at two (2) welding stations.
h.
Review of the manufacturer's suggested variables for gas metal arc (MIG) welding of carbon steel and low alloy steels.
1.
Discussions with shop personnel.~
3.
Findings a
a.
Deviation Enclosure, Item B.
During the review of QAP 107, Revision 03, issued October 13, 1978, it was noted that the welding instructions for setting up the welding equipment indicated that the amperage was to be set at 120/125, which is the setting required for 0.25" plate. However, the welding to be performed was for materials that ranged in thickness from.036" to.048" (18-20 gage).
The inspector was informed that the machines are set in accordance with the manufacturer's chart for the welding
. parameters, which recommends the amperage to be between 50-100 amps for materials of these thicknesses.
Proce-dure 107, Revision 03, is therefore not consistent with the chart being used for production welding. Amperage is a nonessential variable, but the procedure should indicate any change from the stated amperage established by the procedure being used.
Procedure 107 was found to be a qualified procedure for k" material, but not for steel gages with thickness less than k".
b.
Unresolved Item Shop documentation does not clearly designate the welding procedure to be used by number and revision.
Presently
" station planning" is used to control processing which would not document the procedure and its revision that was used on a weldment.
c.
General The velding observed during this inspection was being perfo 'ned by qualified welders. The inspector was informed that management has designated an employee to be responsible for all welding activities.
His employee at present, is attending a twelve (12) week comprehensive welding course.
The inspector reviewed the proposed course outline, and it appears to be a appropriate for area of responsibility of the assigned employee.
G.
Training 1.
Objectives The objectives of this area of the inspection were to ascertain whether approved procedures have been established for the indoctrination and training of personnel performing quality related activities, and that the procedures are consistent with the NRC regulations and applicable Code requirements and the QA Program commitments. Also, to ascertain whether the indoctrina-tion and training procedures are in place and are effectively implemented.
2.
Method of Accomolishment The objectives of this area of the inspection were accomplished by:
. a.
Verification that the training program is being implemented as described in the QA Manual, by review of the records of personnel receiving training. The following documents were reviewed:
(1) QA Manual Section 1, titled " Organization."
(2) General training records of personnel.
(3) QAP-126 dated February 24, 1976, titled " Quality Control Inspection."
(4) Welding Engineer Training Schedule.
3.
Findinos a.
Deviation None.
b.
Unresolved Item The tr
, program, which is in an early stage of develo
....c, currently only accommodates the training of r
QA inspectors. However, the evidence demonstrated that procedures are being developed, and positive steps taken to expand the scope of the training program to include all personnel involved in quality activities. This element of the QA Program will be reviewed and evaluated during a subsequent inspection.
H.
Audits 1.
Objectives The objectives of this area of the inspection were as follows:
a.
To ascertain that procedures have been prepared and approved by the company which prescribes a system for auditing which is consistent with the commitments of the QA Program.
b.
To determine that the audit procedures and schedules are being properly and effectively implemented by the company.
2.
Method of Accomolishment The preceding objectives were accomplished by:
, a.
Review of the QA Manual Section XVII, dated December 18, 1978, titled " Audits."
b.
Review of the current audit program files for audits per-fonned to verify that:
(1) Audits are performed in accordance with checklists, approved procedures, or instructions.
(2) Deficiencies identified by audits require corrective action to be implemented.
(3)
Provisions have been made for re-audit to verify corrective actions.
(4)
Provisions have been established for the audit results to be reviewed by management.
c.
Review of the current audit schedule.
d.
Review of QAP 121, dated January 29, 1979, Revision 4, titled " Audit Program," and QAP 121A vendor audits.
e.
Review of audits performed during 1978, including manage-ment audit.
3.
Findings a.
Within this area of the inspection, no deviation or unresolved items were identified.
b.
The inspector was informed that management has contracted with an independent 4"Jalified auditor to do all audits (management and vendors) for the Burndy/ Husky Company. This program has just been implemented.
Results could not be reviewed during this inspection.
I.
Exit Interview The inspectar met with management representatives (denoted in para-graph A) at the conclusion of the inspection.
The inspector summarized the scope and findings of the inspection.
The management representa-tives had no comment in response to the items discussed by the inspector.
The inspector ieviewed the format to be used by the company when responding to inspection findings which require corrective actiam to be initiated.
.- _ _.