ML19309B705
| ML19309B705 | |
| Person / Time | |
|---|---|
| Issue date: | 08/21/1979 |
| From: | Foster W, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309B692 | List: |
| References | |
| REF-QA-99900372 NUDOCS 8004070091 | |
| Download: ML19309B705 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900372/79-01 Program No. 51400 Cocpany:
The Anaconda Company
' Continental Wire and Cable Corporation Greenwich Office Park 3 Greenwich, Connecticut 06830 Insper+4 rm. at.:
Gulton Road - York, Pennsylvania
. Inspem mr: Conducted: August 7-10, 1979 Inspector:
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W. E. Foster, Contractor Inspector
' Date 1
ComponentsSection II l
Vendor Inspection Branch Approved by:
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D. M _H_unnicutt, Chief Date ComponentsSection II Vendor Inspection Branch Summary Inspection on August 7-10, 1979 (99900372/79-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, and applicable s
l codes and standards, including organization; manufacturing process control; and l
change control. The initial management meeting was also conducted. The inspection,
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involved' twenty-five (25) inspector-hours on site.
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Results: In the three (3) areas inspected, no unresolved items were identified.
i The following deviations were identified.
' Deviations: Organization - practice was not consistent with Criterion V of Appendix B to 10 CFR 50, paragraphs 1.5.1, 1.11.1, and Exhibit No. 1 of the Topical Report (Notice of Deviation, Item A.).
Manufacturing Process Control' practices were not consistent with Criterion V, of Appendix B to 10 CFR 50, paragraphs 2.4.1, 2.4.5, 2.5.1, 2.5.5, 3.2.3, 5.1 and its subparagraph a. of the Topical Report and paragraph III.C. of.
Inspection Standard Practice No. 2000 (Notice of Deviation, Items B. C..D. E.
and F.).
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' Change Control - practice was not consistent with Criterion V of Appendix B
'to 10 CFR 50 and paragraph 3.5.1 of the Topical Report (Notice of Deviation,
- Item G.).
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3 DETAILS SECTION l
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A.
Persons Contacted
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D. D.-.Baughman, Supervisor, Specification Engineering
- A. M.:Coggeshall, Manager, Quality Assurance
- R. E Delp, Technical Manager i
- R. Tilius,' General Manager i
D.LGregg, Plant: En-iaaer
- H._D.. Gr4 ##ith=, AA=inistrative Manager, Quality Assurance i
W. N. Xeffer, Manager, Employee Relations-
- R. J. Montagno, Manager, Manufacturing D. L. Plath, General Foreman
- Attended initial management meeting.
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- Attended initial management meeting and exit interview.
- Attended exit interview.
B.
Initial Management Meeting 1.
Objectives An initi.al, management roeeting was conducted to acquaint the vendor's management with the NRC 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 conducted.
c c.
Describing how inspection results are documented and how proprietary items are handled, including the vendor's opportunity to review the report for the purpose of identifying items considered to_be proprietary.
d.
Describing the vendor's responsibility in responding to 5
identified enforcement items relating to:
(1) Correction of the-identified deviation.
.I (2) Action to be implemented to prevent recurrence.
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4 (3) The dates when (1) and (2) above will be implemented or completed.
e.
Explaining that all reports and communications are placed in the Public Document Room (PDR).
f.
Explaining the publication and function of the " White Book."
3..
Findings-Current custcumers are Arizona Public Service and Tennessee Valley Authority. Products supplied for nuclear generating stations are thermocouples and instrumentation and control wire and cable.
There are six (6) active contracts. The production activity devoted to nuclear is approximately three (3) percent.
C.
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 safety-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 authority and duties of persons and organizations had been clearly established and delineatydinwriting:
(1) Topical Report AWC-75-A, Revision 1, dated November 18, 1976, Section 1 and Exhibit No. 1.
(2) Organization Charts for: General Manager Staff, dated July 1979; Manufacturing, dated July 1979; Engineering, dated July 1979; and Manufacturing Engineering, dated July 1979.
(3) Position Descriptions for: Foreman (Manufacturing), dated May 1975; Specifications Engineer, dated February 1979; and Process Engineer, dated July 1976.
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3.
Findings a.
Deviation From Commitment See Notice of Deviation, Item A.
The General Manager Staff and Employee Relations Organization Chart dated July 1979 depicts a box identified as Plant Manage-ment. Plant Management is a team consisting of the Manufacturing Manager and the Technical Manager who heads the Manufacturing Engineering Department. Further, the organization chart states the Plant Management designation is for compliance with the Quality Assurance Manual. The Manufacturing Engineering Organization Chart dated July 1979 indicates the Quality Assurance Manager reports to the Technical Manager. The Technical Manager does not have overall responsibility for the manufacturing facility as does the Plant Manager shown in Exhibit 1 of the Topical Report AWC-75-A, dated November 18, 1976. Therefore, the level of reporting is not an equivalent as required by paragraph 1.11.1 of the Topical Report AWC-75-A, dated November 18, 1976.
b.
Unresolved Items None."""
D.
Manufacturing Process Control 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 l
had been accomplished in accordance with the established and docu-l mented measures. Additionally, verification of indication of mandatory hold points in appropriate documents.
2.
Method of Accomplishment l
The preceding objectives were accomplished by:
a.
Review of the following documents to verify measures had been established and documented to control manufacturing, inspection and test activities:
E (1) Topical Report AWC-75-A, Revision 1, dated November 18, 1976, Sections 5; 6; 10; 11; 14; and paragraphs 2.4; 2.5; and 3.2.
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6 (2) Inspection Procedure No.~524, dated April 6, 1978, Inspection Procedure for Type ERCP Flame Guard Cable.
(3) Manufacturing Standard Practices, Numbers 3503, undated -
Extruder Screw and Barrel Measurement; 3851, dated April 12, 1976 - MantKacturing Instruction Preparation; and 3900, dated December 28, 1970, Cabling - Component Loading Sequence.
(4) Inspection Standard Practices, Numbers 2000, undated -
In-Process Testing; and 2001, undated - Cable Testing -
Final.
(5) Test Methods, Numbers 2039-1, dated July 18, 1979 - Test Method for VW-1 (Vertical Wire) Flame Test; 2041, dated' February 6, 1978 - Flame Propagation Test (Vertical Cable Tray) 210,000 BTU /Hr; 6005-2, dated July 23, 1979 -
Calibration of Footage Counters; 6006-2, dated December 21, 1978 - Point Verification of Calibration (Insulation Resistance Test Sets); and 6008-1, dated December 21, 1978 - Point Verification of Calibration (Copper Resistance Test Sets).
b.
Revie$'oIthefollowingproductiontagsattachedtohardware
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to verify established and documented procedures had been implemented: Numbers, EN 13673, Item 5, Cable Log No. 5848; EN 12736-A, Item 24, Cable Log No. 6042; EN 12763-A, Item 32, Cable Log No. 6020; 12763-A, Item 33, Cable Log No. 6070.
c.
Review of the following production tags not attached to hardware to verify established and documented procedures had been implemented: Numbers, EN 13680, dated October 28, 1978; EN 13656, dated October 28, 1978; EN 12753-D, dated June 6, 1979; EN 12736-A, dated January 22, 1979;and EN 12735-A, dated January 22, 1979.
3.
Findings a.
Deviations From Commitment (1) See Notice of Deviation, Item B.
(2) See Notice of Deviation, Item C.
(3) See Notice of Deviation,' Item D.
-(4) See Notice of Deviation, Item E.
.(5) See Notice of Deviation, Item F.
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7 Regarding Notice of Deviation, Item D, Engineering Instructions (EN) are moved by means of a routing sheet. The responsible person in a.given department signs or initials the routing
-sheet. Persons interviewed stated that signature or initials on the routing sheet indicated review and approval; however, no procedure was presented to the inspector to support.this contention _ The inspector noted that ens did not provide an area for approval; however, initials of the preparer of,the EN
-appeared on.the EN.
b.
Unresolved Items None.
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 i.
usage at.the location where the prescribed activity is performed.
An additional phase was to verify the measures had been implemented.
2.
Methods of Accomplishement The preceding objectives were accomplished by:
a.
Review of the following documents to verify measures had been established to control changes to software and hardware:
1 (1) Topical Report AWC-75-A, Revision 1, dated November 18, 1976, paragraphs 2.6.5, and 3.5.
(2) Engineering Standard Practice No.1903, dated February 2, 1972 - Sales Order Flow.
g (3) Production Standard Practice No. 4300, dated February 18,'
1976
... Standard Procedure for Processing Sales Order Changes.-
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b.
. Review of the following to verify the procedures had been-j implemented:
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(1) -Date Sheets for: EN 12714-A, Order No. 03-65163, l
EN 12736, Order No. 03-65163; and EN 12759-13, Order l
No. 03-65163.
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(2) Engineering Change Notices and affected Engineering Instruction (ens), Numbers 11081-B, dated February 24, 1977; 12721-A, dated July 16, 1979; 12735-A, dated January 22, 1979; 12753-D,' dated June 6, 1979; 12753-C, dated,
January 22, 1979; 12753-B, dated December 19,1978; and 12753-A, dated October 24, 1978.
'3.
' Findings a.
.Deviatina From Commitment See Notice of Deviation, Item G.
Regarding Notice of Deviation, Item G, changes to Engineering Instructions (EN) are moved by means of a routing sheet. The-responsible person in a given department signs or initials the routing sheet. Persons interviewed stated that signature or initials on the routing sheet indicated review and approval; however, no procedure was presented to the inspector to support this contention. The inspector noted that initials of the preparer of the changed EN appeared on the EN.
Changes to ens are accomplished by means of an Engineering Change Notice (ECN) which contains a provision for approval signature of the Specification Engineer. The ECNs nor the affected ens had been signed or initialed by the Specification Engineer.
b.
Unresolved Items None.
F.
Exit Interview 1.
The inspector met with management representatives de noted in para-graph A. at the conclusion of the inspection on August 10, 1979.
2.
The following subjects were discussed:
a.
Areas inspected, b.
Deviations identified.
c.
Contractor response to the report.
The contractor was requested to structure his response under headings of corrective action, preventive measures, and dates for each deviation.
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' Additionally, management representatives.were requested to notify.
the Connaission in writing if dates require adjustment, commitments require modification, etc.
- 3.
Ifanagement representatives acknowledged the comments made by the-inspector.
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