ML19308C781
| ML19308C781 | |
| Person / Time | |
|---|---|
| Issue date: | 11/15/1979 |
| From: | Brown R, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19308C777 | List: |
| References | |
| REF-QA-99900392 99900392-79-1, NUDOCS 8002010333 | |
| Download: ML19308C781 (16) | |
Text
. __ ____
t i O U. S. NUCLEAR REGULATORY Cor! MISSION OFFICE OF INSPECTION AND ENFORCEt!ENT REGION IV i
Report No.
99900392/79-01 Program No.
51300 L
Company:
Speedway Machine and Tool Company, Inc.
1802 North Luett Street Indianapolis, Indiana
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Inspection Conducted: October 22-26, 1979 J-p Inspectors 1 " $,
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D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch Summary Inspection on October 22-26, 1979 (99900392/79-01)
Areas Inspected:
Initial Management Meeting and implementation of 10 CFR 21 and 10 CFR 50, Appendix B, including QA program, manufacturing process control, audits control of nonconformances and corrective action and pro-curement (weld materials). The inspection involved sixty-four (64) inspector-hours on-site by two (2) NRC inspectors.
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Results:
No deviations from commitment or unresolved items were identified j
in the seven (7) areas inspected, however, one item requiring follow-up was identified (See Details Section, Paragraph E.4).
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2 DETAILS SECTION (Prepared by D. E. Whitesell and Ross L. Brown)
A.
Persons Contacted
- R. L. Aiken, Manager, Quality Assurance A. F. Ellis, Chief Inspector
- 11. W. Tucker, Quality Assurance Engineer
- Denotes those present at exit meeting.
B.
Initial Management Meeting 1.
Objectives The objectives of this meeting were to accomplish the following:
To meet with the company's management and those persons a.
responsible for administration of the company's QA program and to establish channels of communication, b.
To determine the extent of the companies involvement in the commercial nuclear business.
To explain NRC direct inspection program including LCVIP c.
organization VIB inspection methods and documentatio'n.
d.
To describe the NRC evaluation of the AS!!E inspection system.
2.
Method of Accomplishment The preceding objectives were accomplished by a meeting on October 23, 1979. The following is a summary of the meeting:
a.
Attendees were:
- Louis A. Roth, President D. L..Spivey, Vice President for Sales and Engineering _
- Richard L. Aiken, Manager, Quality Assurance
- Tony Alejos, Manager, Engineering
- A. W. Basey, Manager, Manufacturing Kenneth J. Buck, Purchasing Agent
- William Tomamichel, Project Engineer
- N. L. Parker, Supervisor, Weld Shop l
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- Denotes those attendees at both the pre-inspection conference, and the post-inspection conference.
- Denotes attendance at the post-inspection conference only.
b.
The VIB organization was described and its relationship to NRC Region IV and the NRC Headquarters component of the Office of Inspection and Enforcement.
c.
The LCVIP was described including the reasons for its establish-ment, its objectives, its implementation structure, and the more significant program changes, d.
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.
The purpose, scope, and status of the NRC's program for c.
evaluation of the ASME inspection system as an acceptable independent third party was discussed.
f.
The company's contribution to the nuclear industry was discussed including current and projected activity, status of ASME certificates of authorization and third party inspection arrangements.
3.
Results a.
Channels of communications were established as follows:
(1)
Informal contracts (telephone), concerning the scheduling of inspections, or routine day by day matters shall be the Quality Assurance Manager.
(2) Formal correspondence shall be addressed to the President of the company, b.
The inspectors were informed that the Company holds ASME Certificates of Authorization, for "N" and NPT" Stamps which covers the manufacture of Class 1, 2, 3, and MC vessels, Class 2 and 3 tanks, Class CS core support structures, component supports, piping subassemblics, parts and appurte-nances. The stamps expire in January 1980 and the ASME Survey team is currently scheduled to audit the company's QA program November 26, 27 and 28, 1979, for the renewal of its stamps.
The company holds an AIA contract with Kemper Insurance Company to provide iuspection services which is currently being performed on an itinerant basis, i
-. - - _ _,... - -. ~. -.. - -..
4 Although the company is primarily a job shop, it holds contracts with 22 nuclear facilities, of which components for twelve (12) nuclear facilities are in-house, and the nuclear work con-stitutes approximately sixty percent (60%) of the company's present work load.
The design of the nucicar components to be manufactured has been performed by the customers and included in the customer's procurement documents. The company subcontracts its responsi-bilities for stress reports, and other design outputs which are required to be certified by registered professional engineers (PE).
It also subcontracts its heat treatment, radiography, and/or ultrasotic examination activities when such activities are requireit by the code and/or contract commitments. The nuclear components included in the nuclear contracts that are pres-ently in-house includes spent fuel racks for Marble 11i11 (on holl), control rod drive mechanism (CRDM) siesmic plat-form, parts and assemblies and tie-rods for missile shields.
c.
Durint, the tour of the facility it was observed that nuclear materials are clearly identified, and stored in a segregated area. Weld materials are stored in an area which is under the surveillance of the Supervisor of the Weld Shop, and low-hydrogen coated electrodes are maintained in ovens at a temperature sufficient to eliminate the pick-up of_ moisture,.
and that good house-keeping practices were being implemented throughout the shop.
C.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
The manufacturer operates under a controlled system using process sheets or equivalent for all operations including inspections pertinent to component production, b.
The system requires all processes and examination / tests to be performed by qualified personnel using qualified procedures.
c.
The process sheets are required to be prepared including document number and revisions to which production and examinations must be performed, e
5 d.
The process sheets include provisions for the identification of hold / witness points and signoff and date.
2.
. Method of Accomplishment The preceding objectives were accomplished by a detailed review of:
Speedway Machine and Tool Company, Inc. (SMATCO) Quality a.
Assurance Manual (QAM), Section 6.0 including the following procedure:
(1) Procedure No. 6.1, that assigns the responsibility for the preparation and approval of the operations and Process Sheet (travelers), that are included in the Pro-duction Package and Job Package.
The travelers includes the special process procedures (such as NDE and Welding) by number, and spaces for QC and ANI initials and date.
(2) Procedure No. 6.2, describes the manner in which a job is released for production and those persons responsible for the activities.
b.
Operation and Process Sheets for three (3) Shop Orders Nos.
4427-N, 4476-N and 4478-N. These travelers include the size and type of material, material heat code number, operations required to produce the component, applicable drawing and procedure numbers, required inspections.
ANI hold points, signing and dates of inspection and/or hold points, applicable NCR numbers, material cross reference list and Code Data Report.
c.
The Revision Log in the data package for each shop order identified in paragraph C.2.b.
This log identified the applicable approved procedures and drawings and latest revision numbers.
3.
Findings No deviations or unresolved items were identified in this area of the inspection.
L-
6 D.
Control of Nonconformances and Corrective Action 1.
Objectives The objectives of this area of this area of the inspection were to verify that procedures have been established and implemented for:
a.
Disposition of nonconformances that provide for:
(1) The control of nonconforming materials, parts, or components to prevent their inadvertent use or installation.
(2)
Identification, documentation, segregation, and disposition of nonconforming items and notification to affected organizations.
b.
Corrective action that provides for:
(1) Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
(2) Reporting these conditions and the corrective action to
' management.
(3) Assuring that corrective action is implemented and maintained.
2.
Method of Accomplishment The above objectives were accomplished by a review of the following documents:
St1ATCO-QAM, Section 13.0 including the following procedure:
a.
(1) Procedure 13.1, which establishes the manner in which nonconformities are to be identified and documented.
The procedure also assigns the responsiblity for the activity.
It further defines nonconformities as any variation from the requirements of the specification, drawing, contract, code or standards.
i (2) Procedure 13.2, that establishes the method by_which nonconformities will be resolved, it also assigns the responsibility for the activity.
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7 The procedure also defines five (5) available dispositions and specifies who is responsible for the review and concurrence of each disposition.
(3) Procedure 13.3, establishes the method for reporting and obtaining corrective action for conditions adverse to quality, it assigns the responsiblity for this activity.
The procedure also requires the QA manager to review the nonconformity and audit reports and report to the President of trends of conditions adverse to quality, b.
The Nonconformance Report (NCR) file for 1979. This file included NCRs 79-01 through 79-125 that covered both nuclear and nonnuclear contracts.
These reports identified contract information, part name, deficiency, cause, recommended disposition, corrective action and approval, c.
The QA manager's 1979, first, second and third quarter trend analysis reports to the President. The report gave the number of.nonconformances and audit findings, and assigned the cause for each.
d.
Three (3) inspection reports (one dimensional and two (2) magnetic particle inspections) that were responsible for NCRs and identified the applicable NCR number.
3.
Findings No deviations from commitment or unresolved items were identified in this area of the inspection.
E.
Quality Assurance Manual Review 1.
Objectives The objectives of this area of the inspection were to ascertain whether:
a.
The Speedway Machine and Tool Company, Inc. (SMATCO) quality assurance program is clearly delineated in writing and that'it provides for controlling quality activities in a manner which is consistent with the NRC regulations and Section III of the ASME Code.
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8 b.
The Quality Assurance / Quality Control (QA/QC) organization has a reporting path to a level of management that has the authority to enforce the effective implementation of the QA program across the lines of authority and responsibilities of the several departments.
c.
The QA organization is independent of the pressures of costs and scheduling and has the freedom to; (1)
Identify quality problems, (2)
Initiate, recommend or provide solutions, (3) Verify the implementation of corrective action, and (4) Has the authority to control further processing or the use of nonconforming or deficient items or materials until dispositioning has occurred.
d.
The QA program provides for appropriate indoctrination and training of personnel performing quality activities.
2.
Method of Accomplishment The foregoing objectives were accomplished as follows:
Review of the SMATCO Ouality Assurance Manual (QAM), that a.
has been evaluated and accepted by the ASME, to ascertain whether it prevides for controlling quality activities in a manner which is consistent with the NRC regulations and the requirements of Section III of the ASME Code.
b.
Review of the SMAICO organizational chart to verify the following:
(1) Whether the Quality Assurance (QA) organization reports to a level of management that has the authority to enforce ef fective implementation of the QA program across depart-mental lines of authority and responsibilities; (2) Whether the QA staf f is independent of the pressures of cost and scheduling, and has the authority and freedom to:
(a) ' Identify quality problems; (b)
Initiate, recommended, and/or provide solutions; and-k~
9 (c) Verify whether appropriate corrective actions have been implemented.
c.
Review of the Statement of Authority and Policy, dated October 18, 1976, and signed by'the Company's President to ascertain whether:
(a) The SMATCO QA program had been enforced on all of its several departments to ensure ef fective imple-mentation; and (b) The QA Manager has been delegated the authority to cross departmental lines of authority to control further processing of nonconforming and/or deficient items and materials until appropriate dispositioning occurs.
d.
Review of the QAM and Procedure QAP 1.8, dated October 18, 1976, to verify that measures had been established, reviewed, approved and released for implementation, which provides for appropriate indoctrination and training of new personnel and the continuing training of employees, to improve,. and/or maintain, proficiencies in the performance of their assigned duties and the training provided is appropriate for the activities performed.
To test whether the training program is being implemented the following documents were reviewed:
(1) Training records of new employees to verify th'at:
(a) Each subject covered is identified; (b) The personnel in attendance was identified; (c) Each attendee had signed and dated the record; and (d) The duration of each training session was recorded in hours.
(2) Review of the continuinb training records.
It is the responsibility of each department head'to hold' training sessions at intervals not to exceed three (3)-months, those individuals within his ' department that are per-forming quality related activities. The training records reviewed included the Engineering, Manufacturing, and Welding. Departments. The review was performed to verify that:
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10 (a) The training sessions were being conducted at the frequency specified; (b) The subject matter covered was identified and was appropriate for the activities being covered;
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P (c) The attendees had signed or initia11ed and dated the attendance list to document his receipt of the training; (d) The duration of the training was recorded; and (c) The training was certified by the department managers reviewed by the QA staff and distributed and filed as prescribed.
3.
Findings i
No deviations or unresolved items were identified in this area of the inspection.
4.
Follow-up Item 4
It was noted during the manual review, that many of the implementing procedures lacked specificity concerning the who, when and how documented.
In some instances which lacked clear definition as to how an activity was to be performed and documented, inspections of -
those areas were performed to verify that the activity was performed correctly and appropriately documented.
In each instance it was verified that the required activity had been correctly performed and appropriately documented.
This matter was brought to the attention of the QA manager who agreed to be more specific as to when how, who and what activity was required and specify the method of documentation. He informed the inspector that where the QA manual and/or the procedures required more detail it would be revised. He anticipates that this can be accomplished prior.to the re-survey by the ASME for the renewal of the ASME Certificates of Authorization. This survey is scheduled for the last week'in November.
F.
' Audits (Internal) 1.
-Objectives i
The ? objectives-of this area of the inspection were to verify that j
the QA program provides for a comprehensive system of planned
.and periodic audits'to verify compliance with aspects of the
~
11 quality assurance program, which is consistent with the NRC i
regulations, code requirements and contract commitments. Also to-verify that the audit system is in place and effectively irplemented.
2.
Method of Accomplishment The foregoing objectives were accomplished by:
a.
Review of the QA Manual, Procedure 1.6, to verify that pro-cedures have been developed, reviewed,' approved, implemented and are appropriate to the circumstances.
Also to verify that the system provides for audits to be performed in accordance with detailed procedures or checklists, by qualified auditors having no responsibilities in-the area audited.
b.
Review of the Master Audit Planning and Scheduling Sheets for the years 1977, 1978 and 1979, to verify that all aspects of the quality assurance program had been audited in each twelve (12) month period.
c.
Review of 14 audit reports to verify that the audit was in' compliance with the Master Audit Planning and Scheduling Sheet, and to ascertain whether the audits were identifying significant program areas which required corrective action.
d.
Review of the auditor's qualification and training records, to verify that the audits were conducted by qualified auditors and that the auditors had no responsiblilty in the areas audited.
c.
Review of responses from the managers of the Departments audited, acknowledging the audit. findings and describing the corrective action which would be implemented within-the prescribed time.
f.
Review of the Re-audit Reports.to verify that a follow-up audit had been performed within the prescribed time, to verify that corrective action had been implemented and was effective.
g.
Reviewed let'ters from the QA Manager to the President of the company transmitting audit reports, to verify thatE.
the President is provided with 'c'opies-of audit reports 'for his review and comments as' prescribed.
12 h.
Reviewed letters from the President to the QA manager, to verify that the President does review and comment on the audit reports provided him.
3.
Findings a.
From the documents reviewed it was determined that SMATCO has implemented a comprehensive audit system which is consistent with the NRC regulations, code requirements and contract commitments.
It was also determined from the signif-icance of the audit findings, corrective actions initiated and follow-up verification re-audits that the audit system as implemented is effective.
b.
In this area of the inspection no deviations or unresolved items were identified.
a G.
Procurement (Weld Material) 1.
Objectives The objectives of this area of the inspection were to ascertain whether the vendor had developed a system to assure that adequate quality requirements are. suitably included or referenced in the procurement documents, in compliance with the NRC regulations, code requirements, and contract commitments. Also to verify that the system is properly implemented.
2.
Method of Accomplishment The foregoing objectives were accomplished by:
a.
Review of the QAM, Procedure 4.1, to ascertain whether measures have been provided, reviewed, and approved, to ensure that the quality of items and materials specified by the customers purchase order, and/or code requirements, are included on the SMATCO procurement documents.
l b.
Reviewed customers P0 number 546-CPK-271301-DN to verify that the specified code, quality class, materials,_qualifi-cation test requirements were accurately translated onto the material list from which the Purchase Order is prepared, and to' identify notch toughness requirements and impact temperatures.
c.
-Review of Welding Procedure _ Specification (WPS): number 1007, Revision 0, dated April 13, 1979, to identify the following:
13 (1) Electrode filler metal specification, type and grade.
(2) Post weld heat treat (PWHT) time and temperature.
(3) Thickness range of the base metal.
c.
Reviewed SMATCO P0 number 16179 to Weldstar, to verify that the PO obligated the vendor to the following:
(1) Quality System to meet the requirements of Section III Subsection NA, subarticle 3700.
(2) Material to meet ASME B and PV Code Section III, Sub-section NF, Class 1, 1977 edition.
(3) Welding Electrodes to confonn to ASME Section II, Part C, 1977 edition SFA 5.1 Class E 7018.
(4) CMTR required and all characteristics required by code recorded.
Heat number must appear on all material.
d.
Reviewed Receiving Report, to verify that the material heat number was recorded and found to be acceptable, and the acceptability of the material properly verified and documented.
Review of the suppliers Certified Material Test Report (CMTR),
c.
~ dated March 24, 1978, to verify that the heat number had been correctly recorded on the receiving report, that the material conformed to ASME Section II Part C SFA 5.1 Class 1 type E 7018 and to verify the following:
a.
The chemistry was recorded.
b.
As welded test results were recorded.
c.
Test results after 8 hrs a 1150 F were recorded.
d.
The charpy V-norch impact test results at 20 F were recorded.
c.
The suppliers ASME Quality System Certificate number and expiration date were recorded.
3.
Findings a.
The documents reviewed demonstrated that SMATCO has implemented measures to assure that the quality. requirements L
14 established by code and contract commitments are being included on the SMATCO purchase order for weld materials.
b.
No deviations or unresolved items were identified in this area of the inspection.
H.
Part 21 Inspection 1.
Objectives The objectives of this area of the inspection were to verify the following:
Whether 10 CFR 21 had been imposed on SMATCO by any of its a.
customers.
b.
Whether SMATCO has posted Section 206 on the personnel bulletin boards.
Whether SMATCO has the expertise to evaluate the safety c.
significance in the materials and/or items they manufacture for the nuclear industry.
d.
Whether SMATCO has developed measures explaining to whom its employees are to report defects, and who and how this information is to be reported to the Commission and customers affected by the defect.
2.
Method of Accomplishment The foregoing objectives were accomplished as follows:
a.
Discussions with cognizant personnel to ascertain whether SMATCO was contractually obligated to the requirements imposed by 10 CFR, Part 21.
b.
Reviewed the material posted on the employees bulletin boards to verify that Section 206, of Public Law 93-438, was posted as required by the Energy Reorganization Act-1974.
c.
-Reviewed a copy of a letter from the company's President to each employee with copics of Section 206, and 10 CFR 21 attached. The Presidents letter explained the obligation for_
each employee to report any known defects which might adversely affect the quality of the item containing the defect.
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3 15 d.
Discussion with the cognizant personnel to ascertain whether the company has the expertise to evaluate the safety significance of a defect that may be reported concerning the nuclear items which it manufactures.
Discussions with the individual assigned the responsibility e.
for notifying the Commission and its customers concerning any identified defects.
3.
Findings The inspector was informed that 10 CFR 21 has been imposed a.
on SMATCO by its nuclear customers.
b.
The inspector verified that SHATCO has posted both Section 206 of PL93-438, and 10 CFR 21 on the employees bulletin board.
In addition each employee received copies of both Section 206 and Part 21.
c.
The inspector was informed that SMATCO does not have the necessary expertise to evaluate the nuclear safety signifi-cance of items it manufactureres for the nuclear industry, but would notify its customers of such defects and request the customer to perform the evaluation and notify SMATCO whether the defect was of sufficient safety significance to be reportable in compliance with Section 206 and Part 21.
d.
The inspector was informed by the Manager of QA, that SMATCO had identified and reported a defect in a nuclear item purchased by Westinghouse. Westinghouse evaluated the-safety significance of the reported defect and determined that it was not reportable under Part 21.
I.
Exit Meeting The inspectors conducted on exit meeting with the SMATCO management representatives identified in Paragraphs A and B.2.a. at the con-clusion of the inspection.
The inspectors discussed the scope of the inspection and the details of the areas of concern identified during the inspection. Management representatives acknowledged the statements by the inspectors and their comments were for clarification only.
The inspectors also discussed the NRC method of reporting and in-formed those present that theyfwill receive a copy of the inspection y
16 report for their review for any proprietory information they were also informed how to transmit any information they wish deleted.
The White Book information and distribution was also discussed.