ML19275A765

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QA Program Insp Rept 99900367/79-01 on 790625-28. Noncompliance Noted:Inspector Had Not Signed & Dtd Delivery Final Receipt Copy of Purchase Order & Vertical Lines Not Used to Indicate Changes in Std Practice Bulletin
ML19275A765
Person / Time
Issue date: 07/17/1979
From: Foster W, Hunnicutt D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19275A745 List:
References
REF-QA-99900367 99900367-79-1, NUDOCS 7910190093
Download: ML19275A765 (9)


Text

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900367/79-01 Program No. 51400 Company:

Square D Company Assembly Services Division 252 Tippecanoe Peru, Indiana Inspection Conducted: June 25-28, 1979 Inspector: N(

-d 7// c /7 9 W. E. Foster, Contractor Inspector Date Vend Inspection Branch

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i PraAne W 7 /7/2I Approve by:

D4 M. Hudnicutt, Chief, ComponentsSection II

/ Date Vendor Inspection Branch Summarv a-

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Inspection on June 25-28, 1979 (99900367/79-01)

Areas Inspected:

Implementation of 10 CFR 50, Appendix B criteria, and applicable codes and standards, including Quality Assurance Manual review; Quality Assurance Program; change control; manufacturing process control; and organization. The initial management meeting was also conducted. The inspection involved twenty-seven (27) inspector-hours on site.

Results:

In the five (5) areas inspected, no unresolved items or deviations were identified in two (2) areas. The following deviations and unresolved items were identified in the remaining three (3) areas:

Deviations: Quality Assurance Program - Practice was not consistent with Criterion V of Appendix B to 10 CFR 50, and paragraph III.B.4 of Quality Control Proedure No. 120 (Notice of Deviation, Item A.).

Change Control - Practices were not consistent with Criteria V of Appendix B to 10 CFR 50, paragraph I.D.1.b of Standard Practice Bulletin No. 100.001, and paragraph II.B.6 of Standard Practice Bulletin No. 512.404 (Notice of Deviation, Items B. and C.).

Manufacturing Process Control - Practice was not consistent with Criterion V of Appendix B to 10 CFR 50, and paragraph 5.3 of the Corporation Quality Assurance Manual (Notice of Deviation, Item D.).

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2 Unresolved Items:

Change Control - Master Record Routings were being changed with forms other than those identified in the Standard Practice Bulletin (Details Section, paragraph E.3.b.).

Manufacturing Process Control - The inspector was unable to determine that instrumentation used in the cleaning / painting process was indicating accurately because the instrumentation is not under the calibration program (Details Section, paragraph F.3.b.).

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3 Details Section A.

Persons Contacted

  • R. H. Brunner, Plant Manager J. R. Bull, Analyst - Metal Finishing
  • T. A. Cincotta, Supervisor - Utility Sales
  • D. G. Fischer, Chief Design Engineer R. J. Garber, Supervisor - Assembly Engineering M. R. Hendricks, Production Scheduler S. L. Higgins, Analyst - Senior Quality Control
  • L. H. Holden, Manager - Assembly Sales and Engineering
  • G. Q. Lofgren, Engineer - Corporate Quality Assurance S. R. Long, Aralyst - Quality Control R. G. Masten, Supervisor - Laboratory F. J. Morris, Supervisor - I/T Engineering
  • W. G. Nollenberger, Vice President - Power Equipment Group W. E. Rose, Supervisor - Panel Board Design A. B. Sagarsee, Project Engineer
  • L. D. West, Manager - Quality Assurance
  • Attended initial management meeting and exit interview.

B.

Initial Management Meeting 1.

Objectives An initial management meeting was conducted to acquaint the vendor's management with the hTC responsibility to protect the health and safety of the public and to inform them of certain responsibilities imposed on vendors by the " Energy Reorganization Act of 1974" (Public Law 93-438). Those in attendance are denoted in paragraph A.

2.

Method of Accomplishment The preceding objectives were accomplished by:

a.

Describing the historical events that indicated the need for the Vendor Inspection Program (VIP).

b.

Explaining the inspection base and how the inspections are con-ducted.

Describing how inspection results are documented and how proprietary c.

items are handled, including the vendor's opportunity to review the report for the purpose of identifying items considered to be proprietary.

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4 d.

Describing the vendor's responsibility in responding to identified enforcement items relating to:

(1) Correction of the identified deviation.

(2) Action to be implemented to prevent recurrence.

(3) The dates when (1) and (2) above will be implemented or completed.

Explaining that all reports and communications are placed in the e.

Public Document Room (PDR).

f.

Explaining the publication and function of the " White Book."

3.

Findings The inspector was informed that tue company has four (4) active contracts to provide motor control centers, switchboards and panel-boards. Major suppliers are other groups within the Square D Company.

The percentage of production activity devoted to nuclear is less than one.

C.

QA Manual Review' 1.

Objectivies The objectives of this area of the inspection were to verify that the QA Manual addressed the eighteen (18) criteria of Appendix B to 10 CFR 50 and had been endorsed by management as an authoritative document.

2.

Method of Accomplishment The preceding objectives were accomplished by reviewing the Corporation Quality Assurance Manual (QAM) No. A-75.02, dated May 16, 1978, and the Peru Plant Instructions and Procedures to verify they had been endorsed by management and addressed the eighteen (18) criteria of Appendix B to 10 CFR 50.

3.

Findings Within this area of the inspection, no deviations or unresolved items were identified.

The Peru Plant Quality Assurance Manual had been adopted and identified as the Corporation Quality Assurance Manual (CQAM) and will apply to several plants.

Currently,itappliestotheRaleigh,NorthCarolina,18 i179 1

5 and Peru, Indiana, plants.

Corporate Quality Assurance is in the process of reviewing and upgrading as necessary, the Quality Assurance Program of other plants providing safety-related equipment. As the plants satisfy the requirements, they will be added to Appendix A of the CQAM.

D.

Quality Assurance Program 1.

Objectives The objectives of this area of the inspection were to verify that the program had been documented, controls had been established and the program had been implemented.

2.

Methods of Accomplishment The preceding objectives were accomplished by:

Review of the following documents to verify the program had been a.

documented by written policies, procedures, or instructions:

(1) Corporation Quality Assurance Manual, dated May 16, 1978; Sections 3, 7, 8, and 12.

(2) Quality Control Procedures, Numbers 120, dated November 27, 1978; 158, dated September 15, 1976; and 163, dated September 15, 1976.

(3) Standard Practice Bulletin No. 100.013, dated November 9, 1978.

b.

Review of hardware covered by the program to verify identifica-tion had been established.

Review of the following activities to verify the program Fad been c.

implemented: Design Control; Control of Purchased Material, Equipment, and Services; Identification and Control of Materials, Parts, and Components; and Control of Measuring and Test Equipment.

3.

Findings a.

Deviation From Commitment See Notice of Deviation, Item A.

b.

Unresolved Items None.

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6 E.

Change Control 1.

Objectives The objectives of this area of the inspection were to verify that measures had been established to control changes to software and hardware. Also, to verify the measures for software changes included provisions for review, approval, and distribution to and usage at the location where the prescribed activity is performed. An additional phase was to verify the measures had been implemented.

2.

Methods of Accomplishment The preceding objectives were accomplished by:

Review of the following documents to verify measures had been a.

established to control changes to software and hardware:

(1) Corporation Quality Assurance Manual, dated May 16, 1978, Sections 3 and 15.

(2) Standard Practice Bulletins, Numbers ~100.001, dated August 1,1970 (pages 4 and 5 exhibit dates of October 17, 1972', and June 13, 1972, respectively); 500.012, dated June 22, 1973; 500.022, dated September 21, 1976; 512.307, dated November 10, 1977; and 512.408, dated April 26, 1978.

b.

Review of the following to verify the procedures had been implemented:

(1) Drawing Numbers HCM-1438-1N, Revision G, dated July 19, 1978, related Bill of Material, and Design Notice; HCM-0938-2MN, Revision G, dated July 20, 1978, related Bill of Material, and Design Notice; PBD-11713, Revision A, dated April 19, 1978, and related Design Notice; B80005-935-SPL, dated June 26,1979; D80015-092-72-SPL, dated June 26, 1979; 12-07797-SM1, SM12, dated Sne 26, 1979.

(2) Specification Numbers S31037-841, Revision B, dated January 22, 1975; S30318-625, Revision B, dated August 29, 1978, and related Design Notice; S30318-643, Revision A, dated March 17, 1978, and related Design Notice.

(3) Standard Practice Bulletin Numbers 100.006, dated January 25, 1975; 103.013, dated November 9, 1978; 512.404, dated August 19, 1976; and 712.300, dated June 15, 1976.

(4) Twc (2) recipients of Drawings, Specifications and Design Notices.

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7 (5) Reject tags dated June 22, 1979; March 15, 1979; and May 16, 1979; and related hardware.

3.

Findings a.

Deviations From Commitment (1) See Notice of Deviation, Item B.

(2) See Notice of Deviation, Item C.

b.

Unresolved Item Standard Practice Bulletin No. 512.307, dated November 10, 1977, requires that Form No. PE-1014 be used to effect changes to Master Record Routings. The inspector observed that this form was not in use; rather, six (6) new forms wece in use. The inspector was informed the new forms had been in us.- four (4) to six (6) months but the procedure had not been revised due to possible additional changes.

F.

Manufacturing Process Control

- a, :#

1.

Objectives The objectives of this area of the inspection were to verify that measures had been established and documented to control manufacturing, inspection and test activities. Also, to verify these activities had been accomplished in accordance with the established and docu-mented measures. Additionally, verification of indication of mandatory hold points in appropriata documents.

2.

Method of Accomplishment The preceding objectives were accomplished by:

Review of the following documents to verity measures had been a.

established and documented to control manufacturing, inspection and test activities:

(1) Corporation Quality Assurarce Manual, dated May 16, 1978, Sections 5, 9, 10, 11, an?

  • 4.

(2) Quality Control Procedures Nos. 168, dated November 28, 1977; 61, dated January 12, 1977; 64, dated February-22, 1977; and 159, dated September 10, 19

8 b.

Observation of: The Cleaning / Painting process; inspection of a Panel Trim Assembly for first piece approval; assembly and test operations of Motor Contol Centers to verify accomplishment in accordance with established and documented measures.

Review of Shop Work Orders, Routing Sheets, Quality Control c.

Inspection Checklists, and Supplemental Inspection Checklists to verify mandatory inspection hold points had been indicated.

3.

Findings a.

Deviation From Commitment See Notice of Deviation, Item D.

b.

Unresolved Item The inspector was unable to determine that instrumentation used in the cleaning and painting was accurately indicating the medium being measured. This inability was due to the instrumentation not being included in the calibration program. A case in point - a thermometer was indicating 148 F when it should have indicated 155-165 F.according to Special Process Procedure No. B-1 dated December 24, 1977. The inspector was informed that the installed thermometer was defective and the temperature was within range when measured by a pocket thermometer; which incidentally, was not under the calibration program.

G.

Organization 1.

Objectives The objectives of this area of the inspection were to verify that authority and duties of persons and organizations performing activities affecting sety-related functions (achievers and verifiers) had been clearly established and delineated in writing. Also, to verify that performers of the quality assurance functions had sufficient authority and freedom to identify quality problems; to initiate, recommend or provide solutions; and to verify implementation of solutions. Further, the individuals responsible for assuring effective execution of any portion of the quality assurance program had direct access to such levels of management necessary to perform this function.

2.

Methods of Accomplishment The preceding objectives were accomplished by:

Review of the following documents to verify the quality organization was independent and authority and duties had been clearly established and delineated in writing:

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9 (1) Corporation Quality Assurance Manual, dated May 15, 1978, Sections 1 and 2.

(2) Job Description Summaries, dated December 15, 1978, for Production Scheduler, Purchasing Clerk, Approval Drawings Draftsman, Product Technician, Industrial Engineer, and Product Designer.

(3) Standard Practice Bulletins Nos. 500.014, dated April 29, 1977, and 512.404, dated August 19, 1976.

3.

Findings Within this area of the inspection, no deviations or unresolved items were identified.

H.

Exit Interview 1.

The inspector met with management representatives denoted in para-graph A. at the conclusion of the inspection on June 28, 1979.

2.

The following subjects were discussed:

Areas

  • Inspected.

a.

b.

Deviations identified.

c.

Unresolved Items identified.

d.

Contractor response to the report.

The contractor was requested to structure his res;xcse under headings of corrective action, preventive measures, and d.tes for each deviation.

Additionally, management representatives were requested to notify the Commission in writing if dates require adjustment, commitments require modification, etc.

3.

Management representatives comments related generally to clarification of the findings.

1179 123