ML19281B129
| ML19281B129 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1978 |
| From: | Barnes I, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19281B120 | List: |
| References | |
| REF-QA-99900287 NUDOCS 7904260035 | |
| Download: ML19281B129 (10) | |
Text
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U. S. fluCLEAR REGULATORY COMISSION 0FFICE OF IflSPECTION AND EtlFORCEf4EllT m
REGION IV Report No. 99900287/78-02 Program No. 44060 Company:
TRW Mission Manufacturing Company 8760 Clay Road Houston, Texas 77040 Inspection Conducted:
October 30 - flovember 3,1978 3
i s 4 //'7 F Inspector:
om I. Barnes, Contractor Inspector, Vendor Date Inspection Branch Approved by:
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//[JM/77 D. M. Hunnicutt, Chief, ComponentsSection II,
/ Dats Vendor Inspection Branch Summary Inspection on October 30 - November 3, 1978 (99900287/78-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including action on previous inspection findings; followup on possible Part 21 report; material identification and control; procurement control and qualification of personnel (visual examination).
The inspection involved thirty-two (32) inspector-hours on site.
Results:
In five (5) areas inspected no apparent deviations or unresolved items were identified in two (2) areas; the following were identified in the remaining three (3) areas:
Deviations:
Action on Previous Inspection Findings - Committed Quality Control Inspection Instructions and Inspection Report had not baen issued 1
as of this inspection (Enclosure, Item A.); preparation of and compliance J'
with a certain shop traveler not in accordance with Criterion V of i=
10 CFR 50, Appendix B, and Section 5.0 of the Product Assurance Manual
- y (Enclosure, Item B.).
x Material Identification and Control - Control of hinge pin materials through installation not in accordance with Criterion VIII of 10 CFC 50, Appendix B, and Section 5.0 of the Prod ~uct Assurance Manual (Enclosure, Item C.).
79042600 6
2-Qualification of Personnel (Visual Examination) - Visual examination qualification requirements of QCP No. 035 Revision A not fully consistent with Criterion IX of 10 CFR 50, Appendix B, and Section III of the ASME Code (Enclosure, Item D.).
Unresolved Items: Material Identification and Control - Utilization of austenitic stainless steel pin retainers in carbon steel valve bodies (Details Section, C.3.b.).
. DETAILS SECTION A.
, Persons Contacted
- P. J. Koen, Vice President and General Manager
- D. Hanink, Director of Manufacturing J. R. Turner, Director of Technical Operations and Product Assurance Manager
- G. B. Biggers, Manager, Project Quality Engineerlag
- R. F. Kane, Manager, Petallurgy S. P. Buckner, Chief Valve Department Engineer J. D. Harrison, Senior quality Control Engineer J. L. Lindner, Qualit Control Engineer T. Mercer, Supervisor, Inspection H. Morris, Quality Control Engineer
- Attended exit meeting.
B.
Action on Previous Inspection Findings 1.
(0 pen) Deviation (Inspection Report No. 78-01):
Contrary to corrective action commitments, Quality Control Inspection Instructions and Inspection Report had not been issued.
In response to Inspection Report No. 78-01, completion of the committed Quality, Control Inspection Instructions and Inspection Report was revised to August 1, 1978. The inspector ascertained during the inspection that this commitment was still incomplete.
This is a repeat deviation from corrective action commitments (See Enclosure, Item A.).
2.
(0 pen) Deviation (Inspection Report No. 77-02):
Failure of Manufacturing to explicitly follow Method Layout and other work defining documents.
The inspector verified that commitments relative to generation of an integrated routing system were now complete and the system was now in use in manufacturing activities.
Additional commit-ments relative to Quality Engineering review of documentation were still incomplete, however. as a results of the failure to complete the committed Quality. Control Inspection Instruction referenced in 8.1. above.
During review of this activity, an additional deviation from commitment involving use of the new routing system was identified, which is described as follows:
- Section 1.0 of the Product Assurance Manual, paragraph 1.4.7, requires Manufacturing to explicitly follow all Shop Travelers and other work defining documents.
Section 5.0 of the Product Assurance Manual, paragraphs 5.2 and 5.5 requires a listing of applicable operations, methods and procedures in the Shop Traveler and sign-off of operations by the applicable personnel.
Contrary to the above, the following was observed in the Shop Traveler packet for Job No. 80015, QC No. 5999:
a.
Defect removal method and operation were not provided in the repair traveler, issued May 24, 1978.
b.
Operation No. 735 in the repair traveler issued on July 27, 1978, was not signed, although the applicable postweld heat treat operation had been performed on August 21, 1978.
(See Enclosure, Item B.)
In addition to the above, the inspector noted that Operation 740 (Review of heat treat operations) had been signed off as acceptable by QA on the traveler, although Operation 735 in the July 27, 1978, traveler was not signed.
A preliminary penetrant inspection, which was'not listed as an operation in the March 7,1978, traveler, was performed prior to Operation 755 (Final PT of overlay seal surface), resulting in the issue of a Material Discrepancy Report (MDR).
Section 13.0 of the Product Assurance Manual req'uires that MDR number to be recorded in the Shop Traveler at the appropriate operation.
This was not done, in that the inspection was not performed as a defined operation.
3.
(Closed) Deviation (Inspection Report No. 78-01):
Failure of calibration specification to include requirements relative to methods and standards and unauthorized change in calibration frequency.
The inspector verified that a Quality Control Specification, QCS No. 047, Gage and Instrument Calibration and Certification, had been prepared to replace Manufacturing Specification ES 905 Revision K (Eight (8) days after commitment date) Sub-tier proce-dures, dealing with calibration methods, had also been prepared and complied into a Calibration Manual.
Review of QCS 047, however, relative to the March 27, 1978, commitments showed no definition of procedure preparation and maintenance t
. responsibility or referance to specific methods contained in the Calibration Manual. These items were resolved during the inspection by appropriate revisions to QCS 047.
4.
(Closed) Deviation (Inspection Report No. 78-01):
Personal inspection gages not included in calibration program and certain gages without calibration stickers.
The inspector verified that Section 8.0 of the Product Assurance Manual had been revised to reflect gage recall as the primary system of calibration maintenance (paragraph 8.6 and not 8.7 as indicated in the March 27, 1978, responseletter).
It was ascertained, that reinstruction of the Inspection Foreman and review of control status of Inspector personal gages, had not been documented by the former Product Assurance Manager. The inspector established by interview of the Inspection Foreman that the reinstruction had, in fact, occurred and that the inspect-tion qualification system in place, now precluded dimensional measurements being made on nuclear products by new inspection employees. An independent sampling of the control status of inspection personal gages was also performed to verify the adequacy of present controls.
5.
(Closed) Deviation (Inspection Report flo. 78-01): Acceptance of an investment casting manufacturer as a qualified vendor without possession of a documented Quality System Program.
The inspector ascertained, that TRW had been unable to achieve resolution of program deficiencies and site audit deviations with the subject manufacturer, and had removed the manufacturer from the Nuclear Products Approved Vendors List. A review was made of Sections 4.0 and 15.0 of the Product Assurance Manual and QCP-011 to verify that format was now consistent with precluding similar deviations. An additional verification of the current adequacy of the Nuclear Products Approved Vendors List was made by review of audit records and other documentation for a random sample of six (6) vendors from the list.
6.
(0 pen) Unresolved Item (Inspection Report No. 78-01):
Absence of periodic independent assessment of the quality system.
The status of this item was not reviewed during this inspection.
C.
Material Identification and Control 1.
Objectives
. The objectives of this area of the inspection were to verify that material identification and control during manufacturing were in accordance with applicable regulatory, Code and contract requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Procuct Assurance Manual, Section 5.0, Sub-Section 5.1, Revision dated June 16, 1978, " Material, Parts and Components Identification."
b.
Review of Product Assurance Manual, Section 4.0, Revision dated October 20,1978, " Procurement Control," relative to receiving inspection requirements.
c.
Examination of six (6) components at different stages of fabrication relative to identification.
d.
Comparison of identity with identity entered in applicable traveler packages.
e.
Examination of welding electrode ovens for segregation of electrodes in accordance with identity maps.
f.
Review of Cerified Material Test Reports for components identified in c. above and six (6) welding materials to establish acceptance by TRW and to verify compliance with procurement documents.
g.
Review of applicable customer specifications relative to specific material requirements.
h.
Examination of one (1) valve at final assembly relative to materials identification.
i.
Observation of barstock and warehouse storage area relative to materials identification and segregation.
j.
Examination of receiving inspection reports and Certified Materials Test Reports for four (4) heats of barstock.
3.
Findings a.
Deviation from Commitment See Enclosure, Item C.
. b.
Unresolved Items Utilization of a pin retainer material with a significantly greater coefficient of thermal expansion for plugging carbon steel valve bodies, i.e., austenitic stainless steel.
c.
Comments Certified Material Test Reports generated by TRW for castings produced at the TRW foundry have contained a statement,
" Castings are weld free and nonheat treated." This state-ment apparently relates to the internal release system from the foundry and is erroneous at the time of shipment of the completed product.
The heat treat cycle performed on a casting is recorded on the Certified Material Test Report despite the statement and documentation of any weld repairs performed is provided.
D.
Procurement Control 1.
Objectives The objectives of this area of the inspection were to ascertain that:
a.
A system for procurement document control had been prepared and implemented, which was consistent with regulatory, Code and contract requirements, b.
Source selection was made in accordance with QA Program commi tments.
c.
Provisions were made in the QA Program for the evaluation of supplier performance.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Product Assurance Manual, Section 4.0, Revision dated October 20, 1978, " Procurement Control."
b.
Review of Product Assurance Manual, Section 6.0, Revision dated October 20,1978, " Welding Quality Assurance."
c.
Review of Product Assurance Manual, Section 13.0, Revision dated June 16, 1978, "Nonconformities."
- d.
Examination of purchase orders and material reorder notices for six (6) items relative to:
(1)
Evidence of Product Assurance approval.
(2) Definition of technical requirements consistent with Code and customer requirements.
(3) Procurement from an approved vendor, e.
Review of basis of vendor approval relative to QA Program commitments.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
E.
Qualification of Personnel (Visual Examination) 1.
Objectives The objectives of this area of the inspection were to ascertain that:
a.
A written procedure had been prepared, which defines require-ments for qualification of personnel performing visual examination.
b.
The procedure had been implemented and was consistent with Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Quality Control Procedure No. 035 Revision A,
" Procedure for Visual Examination."
b.
Determination of qualification status of inspection personnel.
c.
Discussion with cognizant personnel.
3.
Findings a.
Deviation from Commitment See Enclosure, Item D.
_9 b.
Unresolved Items None.
F.
Followuo on Possible Part 21 Report 1.
Objectives The objectives of this area of the inspection were to ascertain whether the evaluation, corrective action, and defect report were adequate and in conformance with requirements of Part 21 and associated procedures and controls.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of TRW Mission Manufacturing Company report to the NRC, dated September 22, 1978.
b.
Examination of laboratory analysis records with respect to:
(1) Verification of accuracy of reported condition.
(2)
Determination of scope of affected products and status of product analyses.
(3) Date of implementation of additional ladle sample and review of sample agreement relative to carbon content for verification of affectiveness of corrective action.
c.
Examination of Foundry Quality Manual for verification that additional ladle samples was incorporated as a programmatic requirement.
d.
Verification that an inventory had been performed of in-house materials, product analyses were made, and those materials with carbon contents in excess of specification had been eliminated from the nuclear valve identification control system.
e.
Examination of written notifications to four (4) customers for accuracy of reported information relative to laboratory records.
3.
Findings a.
Discontinuance of the application of a hot top compound, Foseco Ferrux APC, to ladies prior to movement from the
. furnaces in the TRW Mission Foundry, has eliminated any further evidence of carbon enrichment in castings relative to the original heat analysis.
b.
The hot top compound was utilized by TRW from May 1977 through August, 1978, with carbon enrichment being shown by product analyses to be typically 0.02 - 0.06%.
c.
Deviation of carbon content from material specification requirements was found in nuclear castings to be confined to Types 316 and 410 stainless steels.,
d.
Affected customers identified to date have been notified of the deviation.
~
e.
In-house nuclear castings with carbon contents in excess of material specification requirements have been segregated and removed from nuclear application.
G.
Exit Meeting An exit meeting was held on November 3, 1978, with the management representatives denoted in paragraph A. above. The inspector summarized the scope and findings of the inspection.
Management had no comments concerning the statements of the inspector relative to the inspection findings.
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