ML19294B306
| ML19294B306 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19294B291 | List: |
| References | |
| REF-QA-99900349 99900349-79-2, NUDOCS 8002280161 | |
| Download: ML19294B306 (4) | |
Text
I Corner and Lada Company, Incorporated Docket No. 99900349/79-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on November 13-16, 1979, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
Criterion V of Appendix B to 10 CFR 50 states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Deviations from these requirements are as follows:
A.
QA Manual Section QN-12.0, paragraph 3.I. states, "The Quality Assurance Manager shall prepare a calendar for auditing the program. At least one section shall be audited each calendar month and the entire program shall be audited within a twelve month period."
Contrary to the above, one (1) section has not been audited each calendar month, and the entire program has not been audited within a twelve (12) month period. Audits were not performed during April, May, July, August, September, and ( -tober, 1979. Certain sections were last audited, as follows:
Process Control, Material Identification, Documentation -
May, 1978; Training - June, 1978; Welding - July, 1978; Audits -
August 31, 1978, and Instructions and Procedures - October, 1978.
B.
QA Manual Section QN-10.0, paragraph 4.I., relative to nonconformities states, " Disposition decision for ' Repair' or ' Accept As Is' shall require the approval of the original design activity and shall be reported to the Authorized Nuclear Inspector by copy of the Nonconforming Material Report and signature obtained prior to precceding with the disposition."
Contrary to the above, the signature of the Authorized Nuclear Inspector was not obtained for five (5) of six (6) nonconforming material reports (NCHR) which had an ' Accept As Is" disposition and the disposition has been completed. The NCMRs and their dates are as follows:
815 (6/1/79); 818 (6/5/79); 828 (6/14/79); 832 (7/20/79); and 833 (7/26/79).
C.
QA Manual Section QN-4.0, paragraphs 4.C. and D. states in part,
" Activities operators shall initial and date the Traveler upon completion of each operation in the fabrication sequence.
Fabrication 8002280){
i 2
may proceed only on items which have successfully passed a required inspection as indicated on the Traveler by the inspector's mark. No further work shall be performed on items which have not been inspected Contrary to the above, the following inconsistencies were observed:
1.
Operation No. 1 (Stamp Material Identification) on the traveler for Shop Order (S0) 8-0193N was not initialed and dated by the activit ies operator after completion, while operation No. 2 (welding and a C.: Inspection Point) had been signed off and dated.
2.
Fabrication proceeded on S0s 8-0495N and 8-0192N, in which required inspections had not been performed, as indicated by lack of inspector's mark on the traveler.
In addition, it was noted that operation 5 on the traveler stated, " Stamp Item 1 with Batch No. AL."
The drawing required the batch number to be stamped on one side of the paddle, with the material type symbol stamped on the opposite side. Numerous paddles were observed to have the batch number and the material type symbol stamped on the same side.
D.
QA Manual Section QN-1.4, paragraph 3. A., states, " Written procedures and instructions, containing checklists as required, shall be prepared for all activities affecting quality."
QA Manual Section QN-4.0, paragraph 4. A states, "The Traveler shall indicate the material requirements, the fabrication routing sequence and inspection authority for each activity." The Travelers designate the manufacturing drawings to be used.
Specification No. ST-150 paragraph 3.A. states, "Each drawing shall be prepared using standard draf ting nomenclature and symbols and shall contain sufficient dimensions, detail and information for the intended purpose."
Contrary to the above, certain drawings were observed in which sufficient information was not delineated to provide for the stamping of material identification.
1.
Drawings A3209-0 and A3210-0 do not designate the physical location of the part en which material identification is to be stamped.
2.
Drawing A3202-1 designates the physical location to which the stamping is to be applied, but does not take into consideration the various size brackets which may be fabricated from the drawing.
The size of the No. I rear brackets is such that the stamping cannot be applied in the location as required by the drawing. This was evidenced on SO 8-0452N.
2 3
E.
Specification No. ST-150, which defines requirements for the preparation and control of drawings, paragraph C states in part, "The following information shall be included as applicable:
Material identification to ASME or ASTM published specification.
." Corner and Lada Co.
(C&L) has implemented a Material Code Symbol List, which allows the use of a specific alpha symbol to designate a specific material type as shown below:
pmbol Material A
SA-36 B
A-108 Grade 1018 L
A-307 Grade B X
A-307 Grade A V
A-515 Grade 65 W
A-515 Grade 70 This system facilitates the marking of material in the shop and is so designated on the drawings.
Contrary to the above, certain drawings have more than one material type listed but just one alpha symbol, while other drawings have the incorrect symbol listed for the specified material type.
Examples are as follows:
Drawing Symbol Material
- 1. A3208, A3209, A
SA-36 or A-515, A3210 Grade 65 or Grade 70
- 2. A3218 A
SA-36 or A108 Grade 1018
- 3. B3511, B3513 X
SA-307 Grade B F.
Specification No. ST-150 paragraph 5 states in part, "Each check and approval as performed shall be indicated on the Product Design Check List (form CL-87) by initial and date under the drawing revision number.
All drawings shall be checked.
. by a competent person other than the person who produced the original drawing.
All drawings shall be reviewed, and approval indicated on the drawing by initial and date of the Engineering Manager. The Engineering Manager shall forward all drawings and check lists to the Quality Assurance Manager for review.
Indication of completion of review by the Quality
--.~
2 4
Assurance Manager shall be by initial and date on the drawing and on the Product Design Check List Contrary to the above, many drawings and subsequent revisions show no evidence of review by a checker, and no initials and dates by either the Engineering Manager and the Quality Assurance Manager. The Product Design Check Lists for the associated drawings, with the exception of one (1), were either not used or were not initialed and dated by the Q2ality Assurance Manager.
(See Detail Section, paragraph F.3.a.(3)).
G.
QA Manual Section QN-6.0, paragraph 3.G. states, " Trainees, Level I and Level II examiners shall be supervised and trained by a Level III examiner. The Level III examiner shall test and certify all examiners to the requirements of SNT-TC-1A-1975." SNT-TC-1A-1975 requires a near dis-tance acuity vision test be given to the applicant being considered for certification.
It furthe requires annual vision tests be given thereafter.
Contrary to the above, two (2) personnel were certified as Level II examiners on June 29, 1979, and July 16, 1979 without being given vision tests and they have been performing and signing for nondestructive examinations.