ML19289E018
| ML19289E018 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19289E012 | List: |
| References | |
| REF-QA-99900349 NUDOCS 7903210352 | |
| Download: ML19289E018 (6) | |
Text
Ccrner and Lada Company, Inc.
Docket No.
99900349/78-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on November 13-17, 1978, it appeared that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
Criterion XV of Appendix B to 10 CFR 50 states in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
These measures shall include, as appropriate, procedures for identi.
ation documentation, segregation, disposition, and notification tr
- d organizations...."
QA Manual Section QN 10.0, paragraph 4. states in part,
. All items or activities judged by Quality Control to be nonconforming shal1 be reported on form CL-46 ' Nonconforming Material Report' or CL-47
' Purchased Nonconforming Material Report' to the Quality Assurance Manager. Nonconforming material shall be identified by Quality Control by tagging with numbered green hold tags (form CL-39)...." The Purchased Nonconforming Material Report (PNMR) requires the recording of the hold tag number, and the hold tag requires the recording of the PNMR number for cross referencing and identification purposes.
Contrary to the above, a review of fourteen (14) open PNMRs and their respective hold tags revealed that eight (8) PNMRs had the wrong hold tag numbers recorded and eight (3) hold tags had the wrong PNMR numbers recorded.
B.
Criterion XV of Appendix B to 10 CFR 50 states in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
. Nonconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."
QA Manual Section QN 10.0, paragraph 4. states in part, ".
. All items or activities judged to be nonconforming shall be reported on Form CL-46 ' Nonconforming Material Report'.
The decision to return purchased nonconforming items to the vendor or to rework production items may be made by the Quality Assurance Manager.
For any other disposition of nonconforming items, the decision shall be made by a permanent two member Material Review Board (MRB).
The MRB shall consist of the Qaality Assurance Manager, who shall act as chaiman, and the Engineering Manager...." Form CL-46 requires documentation of I'RB decision and MRB signatures.
7903210352 Paragr2Dh 5. states, "If the MRB or a member of the MRB decides to request corrective action, (sic) Corrective Action Request (form CL-43) shall be completed and tne number recorded on the Nonconforming Material Report (LMR)."
Contrary to the above:
1.
iWR 6. 728 was dispositioned " Accept As Is" and completed on September 28, 1978, without the decision being made by the full MRB in that the Engineering Manager did not sign the fiMR to indicate concurrence.
2.
flMR No. 726 dated August 8,1978, documented a nonconformance, and a disposition which had no MRB signatures signifying concurrence, and Was signed off as being complete on August 10, 1978. Additionally, corrective action was recommended, but a Corrective Action Request was not issued.
3.
NMR No. 715 documented two (2) discrepancies, but the disposition, which was concurred with by MRB and dated April 21, 1978, addressed just one (1) of the discrepancies.
There was no evidence to indicate that the inadvertent use of these nonconforming parts had been prevented. (See DetailsSection I, paragraph C.3).
C.
Criterion XVI of Appendix B to 10 CFR 50 states, "4easures shall be established to assure that conditions adverse to.4uality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
QA Manual Section QN 10.1, paragraph 3. states in part, "The Quality Assurance Manager shall review quarterly all Nonconforming Material Reports,... and other items where corrective action may be warranted, report conditions which require corrective action to the President and Vice President in writing....
Corrective action shall a taken by the assigned department or individual and the action followed and expedited by Quality Control to completion."
Paragraph 4. states in part, "... The Quality Control Manager shall record, follow-up and document the action taken."
Contrary to the above:
1.
Conditions which required corrective action based upon quarterly reviews of flonconforming Material Reports, have not been reported to the President and Vice President in writing.
2.
A review of all closed Corrective Action Requests (Numbers 1 through 7 and dated from August 26, 1977 to July 24, 1973) revealed that there has been no indication or documenting of follow-up activities on actions taken.
D.
Criterion XVI of Appendix 3 to 10 CFR 50 states in part, "!'easures shall be established to assure that conditions adverse to quality,.
and nonconformances are promptly identified and corrected...
The identification of the significant condition the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
In addition to the above, ASME Code Section III, Subarticle NCA-4134.16, Part H states, "The requirements shall also extend to the performance of the subcontractor's corrective action measures."
Contrary to the above, the Corner and t.1da Company, Inc. (CSL) QA Manual does not address tne requirements being extended to the performance of a subcontractor's corrective action measures.
E.
Criterion VIII of Appendix B to 10 CFR 50 states in part, " Measures shall be established for the identification and control of materials, parts, and components, includir:g partially fabricated assemblies.
These measures shall assure that identification of the item is maintained by heat number, part number, serial number, or other appropriate mecns, either on the item or on records traceable to the time, as required throughout fabrication, erection, installation, and use of the item.
QA Manual Section QN 4.1, paragraph 4. states in part, "The Quality Control Manager shall be responsible for assuring all incoming process material is identified..
(and) shall be responsible for insuring all material in process is identified.
Standard Specifications ST-201-0 and 202-0 state in part.
"All material for which identification is lost shall be tagged and disposed of in accordance wi th Standard Speci fication ST-642 'Nonconformities'...."
" Standard Specification ST-642, paragraph 4. states in part "... Nonconforming material shall be identified by the use of... green hold tags...."
Contrary to the above, certain material / parts in which identification had not been maintained, had been moved to The Hold Area and were not identified with green Hold tags or any other identification, i.e. one (1) box of approximately 100 assembled clamps, pins and cotter pins, and two (2) boxes totaling approximately 75 unassembled clamps.
F.
Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings..."
QA Manual Section QN 4.0, paragraph 4. states in part, "... The Travelers shall provide space for the initial or stamp of the inspector for activities inspected... Activities operators, shall initial and date the traveler upon completion of each operation in the fabrication sequence." Shop Order 6-6113N, Variable Spring Top Coils, required the use of Drawing No. A-1004-2 which delineated the location of the batch number and material identification symbol as being on the plate opposite the welded side.
Operation 1 and 2 of the traveler (Stamp Batch No. AB and weld item 1 and 2) had been signed off as being accomplished and inspected.
Contrary to the above, the batch number and material identification were stamped on the welded side of the plate, which when assembled, would not allow the identification to be visible.
G.
Criterion IX of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
QA Manual Section QN 6.0 paragraph 3. states in part, "The Level Ill Examiner shall test and certify all examiners to the requirements of SNT-TC-1A-1975.
Certification of NDE examiner qualification shall be made on form CL-43 'NDE Personnel Qualification Record' SNT-TC-1A-1975 paragraph 6. states in part, "... To be considered for certification, a candidate shall satisfy one of the following criteria for the applicable NDT level.
Documented training and/or experience gained....
" Paragraph 8. states in part, "To be considered... NDT personnel must meet the applicable requirements....
The examination to verify physical and technical qualifications shall consist of the following:
a.
Physical... b.
General (Written)... c.
Specific (Written)
... d.
Practical...."
Contrary to the above, The NDE Personnel Qualification Records for the two (2) Level II Visual Examiners show that they received u training and had no experience, and no specific examinations were given.
H.
Criterion IX of Appenix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and acconplished by qualified personnel using qualified procedut es in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
QA Manual Section QN-6.0, paragraph 3. states in part, ".
NDE (nondestructive examination) procedures for the five testing methods (RT, MT, PT, VT, UT) shall be prepared and approved... Each procedure shall be qualified by actual performance... The procedure shall be demonstrated to the satisfaction of the Authorized Nuclear Inspector I
(ANI) whose acceptance shall be indicated by signature and date on the quali fica tion record. "
Contrary to the above, the visual examination procedure, ST-305 (which is the only ASME Code required NDE performed at C & L) has not been demonstrated to the satisfaction of the ANI as evidenced by the lack of his signature and date on the qualification record.
I.
Criterion VIII of Appendix B to 10 CFR 50 states in part, " Measures shall be established for the identification and control of materials...
These identification and control measures shall be designr _ to prevent the use of incorrect or defective material, parts, and c mponents."
o QA Manual Section QN-5.0, paragraph 3. states in part, " Low hydrogen electrodes shall be bulk stored in hermetically sealed cans.
Once cans of low hydrogen electrodes are opened, the entire content shall be transferred to a controlled heat holding oven, the temperature of which shall be maintained in accordance with the material manufacturer's recommendations...."
Contrary to the above, approximately 200 Type 7018 and 9018 electrodes of various sizes had not been transferred to a controlled, heat holding oven, in that opened cans were observed in the weld material storage area.
J.
Criterion IX of Appendix B to 10 CFR 50, states in part, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
QA Manual Section QN-5.0, paragraph 3. states in part, The welding procedure to be used for each joint shall be indicated on the traveler by the welding engineer." The traveler requires that weld material identification (Heat Code) be recorded.
4 Weld material shall be disbursed from the store room by the s* ore room attendant, only upon presentation of a properly prepared requisition (form CL-54) signed by the area foreman.... The store room attendar.
shall place the material in a portable oven, indicate the material Heat Code on the requisition, sign the requisition, retain cne copy and attach the duplicate copy to the portable oven.
He shall also provide the welder with a copy of the weld procedure indicated on the requisition. The welder shall sign the requisition to indicate receipt of the material and the welding procedure....
Each qualified welder shall be assigned an identifying stamp, uniquely numbered,
.vhich shall be stamped adjacent to all welds produced by that welder.
If size or configuration of the item does not permit stamping, the welder's number shall be indicated on the Traveler."
Contrary to the above:
1.
The weld material Heat Code documented on the traveler for Shop Order 6-56341 as being used on Joints 1 and 2, did not agree with the weld material Heat Code documented on the weld material requisition. The traveler stated type 7018 Heat Code A-154 which is size 3/32" and the requisition stated type 7018, Heat Code B-116 which is size 1/8."
2.
Just one (1) of the two (2) joints being welded on Shop Order 6-5634tl had been stamped with the welder's identifying stamp, even though the size or configuration did not preclude stamping.
K.
Criterion IX of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestruc.tive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
ASME Code Section III, Subsection flF-4231.1 states, " Tack welds used to secure alignment shall either be removed completely, when they have served their purpose, on their stopping and starting ends shall be properly prepared by grinding or other suitable means so that they may be satisfactorily incorporated into the final weld.
Tack welds shall be made by qualified welders using qualified welding procedures.
When tack welds are to become part of the finished weld, thev shall be visually examined and defective tack welds removed."
Contrary to the above, it was observed during several in-process SMAW operations requiring the use of tack welds, that tack welde were neither removed commpletely nor were the stopping arid star.inq ends properly prepared and visually examined prior to incorporation into the final welds.