ML19309C195
| ML19309C195 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1979 |
| From: | Foster W, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309C164 | List: |
| References | |
| REF-QA-99900379 99900379-79-1, NUDOCS 8004080287 | |
| Download: ML19309C195 (7) | |
Text
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'v' U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900379/79-01 Program No. 51400 Company:
Johnson Controls, Incorporated Systems and Services Division 507 East Michigan Avenue Milwaukee, Wisconsin 53201 Inspection Conducted: October 15-19, 1979.
Inspector:
-)/ f lf' i I /y-/7 9 W. E. Foster, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch
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Approved by:
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D. H. Hunnicutt, Chief 4-ComponentsSection II
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Vendor Inspection Branch Summary:
Inspection on October 15-19, 1979 (99900379/79-01).
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, and applicable codes and standards, including organization; quality assurance program; and change control, which was not completed. The inspection in-volved twenty-eight (28) inspector-hours on site.
Results:
In the three (3) areas inspected, no deviations or unresolved items were identified in one area. The following deviations and unresolved items were identified in the remaining two (2) areas:
Deviations:
Quality Assurance Program practices were not consistent with Criterion V of Appendix B to 10 CFR 50; paragraph 6.00 of Standard Practice Instructions No. QA-C-21, dated November 29, 1967; paragraph 2.01.6 of Standard Practice Instructions No. QA-T-53, dated August 30, 1979; paragraph 3.01 of Standard Practice Instructions No. QA-C-15, dated August 18, 1967; and paragraph 4.5 of Standard Practice Instructions No. 57-21, dated November 1, 1972 (Notice of Deviation, Items A, B, C, and D).
Change Control practices were not consistent with Criterion V of Appendix B to 10 CFR 50, and paragraph 3.13.2 of Engineering Drafting Department Standard No. EC-1020, dated December, 1976.
(Notice of Deviation, Item E).
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..__m t-2 Unresolved Items: Quality Assurance Program - there is no apparent require-l ment to initiate test procedures for conducting tests in the Mechanical-Pneumatic Test Laboratory (Details.Section, paragraph D.3.b.(1)).
There is no apparent requirement for initiating Certificates of Compliance at remote facilities (Details Section, paragraph D.3.b.(2)).
Change Control - An apparent conflict exists between Standard Practice 1
Instructions No. 55-6, dated August 2,1976, and Engineering Drafting Depart-ment Standard No. EC-1040, dated November, 1976, regarding the preciseness.of description of changes on the Engineering Change Notice (Details.Section, paragraph E.3.b.).
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DETAILS SECTION A.
Persons Contacted
- M. Anderson, Staff Analyst - Quality Engineering
- B. L. Fagg, Manager - Laboratory Services
- D. R. Fischer, Manager - Quality Assurance R. R. Fitzgerald, Purchasing Agent
- J. E. Hamann, Supervisor - Laboratory Services M. T. Kuchta, Technician B. R. Shultz, Engineer - Senior Process Development D. A. Taipala, Supervisor - Engineering Drafting S. W. Wardinski, Supervisor - Custom Orders H. D. Whitenight, Director - Quality Assurance (Systems Engineering and Construction Division)
- R. D. Wilson, Vice President and General Manager
- T. Wysocki, Manager - Quality Engineering
- Attended initial management meeting and exit interview.
- Attended exit interview.
- Attended initial management meeting.
B.
Initial Management Meeting 1.
Objectives An initial' management meeting 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 con-ducted.
c.
Describing how inspection results are documented and how pro-prietary items are handled, including the vendor's opportunity to review the report for the purpose of identifying items con-sidered to be proprietary.
d.
-Describing the vendor's responsibility in responding to identi-fied enforcement items relating to:
(1) Correction of the identified deviation.
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2 (2) Action to be implemented to prevent recurrence.
(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.
f.
Explaining the publication and function of the Licensee Con-tractor and Vendor Inspection Status Report, NUREG-0040.
3.
Findings The Systems and Services Division also has responsibility for a foundry, machine shop, plating and heat treating facility in Milwaukee and an assembly facility in Georgetown, Kentucky.
Products supplied for use in Nuclear Generating Stations are actuators, dampers and temperature transmitters.
C.
Organization 1.
Objectives The objectives of this area of the inspection were to verify that authority and duties of persons and organizations performing activ-ities 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 implementa-tion 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 the quality organization was independent and authority and duties had been clearly established and delineated in writing:
a.
Quality Assurance Operations Manual,Section III dated August 10, 1979, and i
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b.
Position Descriptions for: Process Engineering Technician; Quality Assurance Supervisor; Design and Development Manager; and Inspector.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
The NRC inspector met with Mr. H. D. Whitenight, Director of Quality Assurance in the Systems Engineering and Construction Division (SECD) for the purpose of becoming better informed regarding the organization of Johnson Controls, Incorporated. SECD has Operations Offices located in the Eastern, Southwestern, Midwestern, and Western United l
States. These offices receive contracts and/or purchase orders for services and/or hardware for nuclear generating stations.
In addi-tion, SECD is responsible for a panel assembly facility located in Poteau, Oklahoma.
D.
Quality Assurance Program 1.
Objectives The objectives of this area of the inspection were to verify that the program had been documented, controls had been established, and the program had been implemented.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following documents to verify the program had been documented by written policies, procedures, or instructions:
(1) Quality Assurance Operations Manual, Sections II, V, VI, VII, XIII, and XVII.
All sections were dated August 10, 1979.
(2) Standard Practice Instructions, Nos.:
(a) QA-I-13, Revision 3, dated August 25, 1975, (b) QA-I-49, Revision 2, dated December 21, 1973, (c) 57-26, dated February 1, 1968, (d)
QA-C-21, dated November 29, 1967, b
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4 (e) 25-1, dated August 20, 1973, (f) ESP-24, dated January 12, 1968, (g)
QA-C-15, dated August 18, 1967, (h)
QA-T-53, dated August 30, 1979, and (i) 57-21, dated November 1, 1972.
b.
Review of the following activities to verify that the program had been implemented:
Instructions, Procedures, and Drawings; Document Control; Control of Measuring and Test Equipment; and Corrective Action.
3.
Findings a.
Deviations From Commitment (1) See Notice of Deviation, Item A.
(2) See Notice of Deviation, Item B.
(3) See Notice of Deviation, Item C.
(4) See Notice of Deviation, Item D.
b.
Unresolved Items (1) The Mechanical-Pneumatic Test Laboratory conducts hard-ware audits and tests. Tests are conducted on hardware manufactured by Johnson Controls as well as hardware manufactured by other compar.ies.
Apparently, no require-ment exists for initiating test procedures to conduct such tests.
The contractor should evaluate this activity for the pur-pose of establishing requirements to initiate procedures for conducting tests in the Mechanical-Pneumatic Test Laboratory.
(2) An unnumbered document dated November 11, 1975, entitled, Quality Assurance Performance Verification Certification Nuclear Power Stations, requires that the Quality Control Government Coordinator sign the Certificate of Compliance.
The NRC inspector noted that a Certificate of Compliance for hardware shipped to a customer from the Georgetown, Kentucky facility, bore the signature of the Quality Control
5 Supervisor at that facility.
It was also noted that no provisions had been made for such an occurrence.
The contractor should establish requirements for initiating-Certificates of Compliance at remote facilities.
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 in-cluded provisions for review, approval, and distribution to and usage at the location where the prescribed activity is performed.
An additional phase was to verify the measures had been implemented.
2.
Methods of Accomplishment 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) Quality Assurance Operations Manual,Section IV dated August 10, 1979.
(2) Engineering Draf ting Department Standards, Nos.:
(a) EC-1000, dated November, 1976, (b) EC-1020, dated December, 1976, (c) EC-1040, dated November, 1976, and (d) EC-1400, dated November, 1977.
(3) Standard Practice Instructions No. 55-6, Revision 2, dated August 2, 1976.
b.
Review of the following documents to verify that the established measures had been implemented:
(1) Engineering Change Orders, Nos.:
(a)77-102, dated February 16, 1977, (b)77-172, dated March 21, 1977, j
(c) 78-66, dated February 2,1978, f
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6 (d) 78-70, dated February 10, 1978, (e)78-250, dated June 2, 1978, (f)78-254, dated June 26, 1978, (g)79-183, dated June 11, 1979, (h)79-252, dated August 1, 1979.
i (2) Engineering Change Notices, Nos.:
(a)77-110, dated March 29, 1977, (b)77-224, dated May 18, 1977, (c)77-272, dated July 7, 1977, 2
(d)78-235, dated June 13, 1978, and l
(e) 79-70, dated March 28, 1979.
(3) Purchase Specifications, Nos.:
~(a) 02-16-452, dated September 29, 1977, and (b) 02-16-746, dated June 12, 1975.
(4) Drawings, Nos.:
(a)37-170, dated October 2, 1975, (b)37-173, dated October 2, 1975, (c)37-192, dated August 6, 1975, and (d)34-131, dated June 23, 1975.
3.
Findings a.
Deviation From Commitment See Notice of Deviation, Item E.
I b.
Unresolved Item Standard Practice Instructions No. 55-6, dated August 2, 1976, requires a precise detailed description, on the Engineering
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Change Notice, of every change, na matter how minor.
Engineering Draf ting Department Standard No. EC-1040, dated November 1976 permits a general statement rather than a detailed listing under certain conditions.
The contractor should review these documents and make the adjustment necessary to resolve this apparent conflict, c.
Comments The NRC inspector lacked sufficient time to complete this area of the inspection.
F.
Exit Interview 1.
The inspector met with management representatives denoted in para-graph A. at the conclusion of the inspection on October 19, 1979.
2.
The following subjects were discussed:
a.
Areas inspected.
b.
Deviations identified.
c.
Unresolved items identified.
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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.
Additionally, management representatives were requested to notify the Commission in writing if dates require adjustment, commitments require modification, etc.
3.
Management representatives acknowledged the comments made by the inspector, and requested clarification of one unresolved item.
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