ML19309D641
| ML19309D641 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1980 |
| From: | Sutton J, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309D622 | List: |
| References | |
| REF-QA-99900302 99900302-80-1, NUDOCS 8004110057 | |
| Download: ML19309D641 (7) | |
Text
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O' U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900302/80-1 Program No. 51300 Company:
Western Piping and Engineering Co. Inc.
1485 Yosemite Ave.
San Francisco, California 94124 Inspection Conducted:
January 28-February 1, 1980
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2-2/-70 Inspector:
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W. Sif'tton, Contractor Inspector Date mponentsSection I Vendor Inspection Branch Approved by:
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m D. 1. Whitesell, Chief
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'Da'te ComponentsSection I Vendor Inspection Brand Summary Inspection on January 28-February 1,1980.
Areas Inspected:
Laplementation of 10 CFR 50, Appendix B Criteria and applicable ; odes and standards, including action on previous inspection findings, procurement control, nonconformance and corrective action, Authorized Nuclear Inspector (ANI) interface and review of vendors activities.
The inspection involved twenty eight (28) inspector hours on site.
Results:
In the five (5) areas inspected no apparent deviations or unresolved items were identified in two (2) areas.
The following were identified in the remaining three areas.
Deviations:
Previous inspection findings.
Failure to take committed corrective action / preventive measures as committed on WP&E letter of April 4,1979, relative to audits of NDE Personnel Records. (Notice of Deviation, Item A).
Procurement - 1, the QA manager was not reviewing all Purchase Orders, 2, Purchase Orders issued to vendors not listed on Qualified Vendors List.
(Notice of Deviation, Item B) Nonconformance, Corrective Action-1, Nonconformance Reports (NCR) not being prepared as required by QA Manual, 2, NCRs not retrievable within a specified time.
(Notice of Deviation, Item C)
Unresolved Items None.
8001100 Qh L
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2 DETAILS SECTION A.
Western Piping and Engineering Company, Inc. (WP&E)
S. Bobowski, Production Manager
- J. Data, Project Manager
- J. C. Flaherty, Vice President
- K. D. Friedman, Project Manager
- M: Wright, Project Manager Department of Industrial Safety, State of California
- R. M. Johnson, Safety Engineer Authorized Nuclear Inspector (ANI)
- Denotes those attending exit interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Inspection Report 79-01) Failure to identify responsibilities, level of authority and lines of communication for subcontractors. The inspector verified that WP&E organization chart and Delegation of Authority and Responsibility have been incorporated into the QA Manual.
2.
(Closed) Deviation (Inspection Report 79-01) Welding Procedure Specification (WPS) Packages did not contain required documentation.
The inspector verified that procedure P-0500-001-1 has been developed and is being implemented.
Additional changes to the QA manual are to be made to indicate that the QC manager will maintain the welder qualification records.
This change presently has been documented only by an inhouse memo.
3.
(Closed) Deviation (Inspection Report 79-01) NDE personnel records did not meet requirements of paragraphs 10.3.2 and 10.3.3 of the QA manual. A twice yearly audit of the WP&E NDE Personnel Quali-fication file as committed to in the WP&E April 4, 1979 response letter had not been performed.
This is a deviation from corrective action commitments.
(Enclosure, Item A) 4.
(Closed) Deviation (Inspection Report 79-01) Internal audits and Audit records did not meet requirements of Paragraphs 18.5 and 18.12.1 of the QA manual.
The inspector verified that the QA manual had been revised to indicate the audit frequency. Training Records have been developed and Internal Audits have been performed.
The inspector reviewed sample documentation records on the above activities.
3 C.
Procurement Control 1.
Objectives The objectives of this area of the inspection were to ascertain that:
a.
A system for procurement document control had been prepared and implemented, which was consistent with regulatory, code and contract requirements, b.
Source selection was made in accordance with QA Program commitments.
c.
Provisions were made in the QA Program for the evaluation of supplier performance.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the QA manual, Section 4.0 b.
Review of the Qualified Vendor list dated January 24, 1980 c.
Review of Commercial Nuclear Purchase Orders (P.O.s)
Nos. 81559, 205-AK480, 205-AJ948, 12401, 12645, 12642, 12453, 12145, 12438 and 12654 for compliance to required QA review and validation.
d.
Review of P.O.s and specifications to determine if the tech-nical code and customer requirements have been indicated in the vendors P.O.
e.
Discussions with cognizant personnel.
3.
Findings a.
Deviation, See Notice of Deviation, Item B.
b.
The inspector reviewed Eleven (11) Purchase Orders during the course of the inspection to determine if P.O.s were being reviewed by the QA manager.
P.O.s involving code items were found to have been reviewed and accepted by.the QA l
manager.
P.O.s were also reviewed for noncode items to i
be fabricated under the requirements of 10 CFR 50, Appendix l
B requirements.
These P.O.s had not been forwarded to the l
l l
4 QA manager for review and validation.
WP&E management had issued a directive, D-0401-001-0 dated November 11, 1979 indicating that the vendor did not need to be listed on the Company's qualified vendors list. These noncode P.O.s had not been forwarded to the QA manager.
Twelve (12) P.O.s had been issued to nonqualified vendors.
c.
Unresolved Items None.
D.
Nonconformance and Corrective Action 1.
Objectives The objectives of this inspection were to verify that:
a.
A system for control of nonconformances and corrective actions has been established and is consistent with NRC regulations, and QA Program requirements; and b.
The system is properly implemented.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
Review of the QA manual Section 15, Nonconforming Items, a.
b.
Review of the corrective action log.
c.
Review of selected Nonconformance reports (NCR).
d.
Inspection of the designated hold and segregation areas.
e.
Discussion with cognizant personnel.
3.
Findings a.
Deviations See Notice of Deviation, Item C.
b.
During the inspectors review of current nonconforming items, it eras noted that nonconforming reports were not being generated as required by the QA program procedures.
5 inspectors were directed to issue a house memo in lieu of NCRs.
Memo's are not included in the QA program for the control of nonconforming items.
In addition, the inspector requested twelve (12) randomly selected NCRs from the NCR log for his review.
The inspector was presented with only four (4) of the twelve (12) requested NCRs. He was informed that the remaining NCRs could not be located.
The time period was in excecs of twenty-four (24) hours.
It was determined that the NCR docu-mentation system is not being implemented and effectively controlled as required.
c.
Unresolved Items None.
E.
Authorized Nuclear Inspector (ANI) Interface 1.
Objectives The objectives of this area of the inspection were to ascertain whether procedures had been prepared and approved, which describes the system to be implemented for the achievement of interface activities with the ANI, and that the identified activities are consistent with the NRC rules, Code requirements, and the QA Program commitments.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished as follows:
a.
Review of Westeri Piping and Engineering Company's QA Manual to ascertain whether the system provides for interface with the ANI and/or the Authorized Inspection Agency (AIA) to re-view the Design Specification (DS), and provide the inspection services, required by code, of all code items covered by the customer's order and DS.
b.
Review of nonconforming reports to verify that changes in the customer's design specifications (DS) are reviewed with the ANI to inform him of the status of the inspections and tests of the items when it is removed from the manufacturing process.
Review of QA Manual, to verify that measures have been provided c.
to make available Material Certifications and the QC Source and/or Receiving Inspection Reports, for review by the ANI, and that such reviews are documented.
d.
Review of QA Manual, to verify that a system has been provided to maintain the identification of materials, and that the iden-
6 tification is transfered when it becomes necessary to divide the material, also to verify that the ANI is provided the opportu-nity to verify that the identification of material is properly maintained and documented.
e.
Review of OA Manual; to ascertain whether measures have been established for the ANI to witness any welding procedure, and/or any welder performance qualification tests, and to request the requalification of any procedure of welder, to ensure proper qualification and/or acceptable welding performance.
f.
Review of QA Manual, to verify that the program provides for the application of the code stamp only with the authorization of the ANI after accetable pressure testing, and the certifi-cation of the Manufacturer's Data Report, and only in the presence of the ANI.
g.
The Daily Log Book maintained by the ANI was reviewed, to verify that WP&E is making its QA/QC documents available to tha ANI for his review, to provide assurance that the code requirements are complied with and that the product quality has been achieved.
3.
Findings The ANI activities as documented in his log book, and by docu-ments reviewed, supports a finding that the vendor is properly imple-menting its interface responsibilities with the ANI in a manner consistent with the NRC rules, Code requirements, and its QA pro-gram commitments.
The ANI is an itinerant inspector, on call by the vendor.
F.
Review of Vendor's Activities 1.
Objectives The objectives of this area of the inspection were:
a.
To review the nuclear activity and work load to assess their impact on future NRC inspections.
b.
Evaluate the vendor's fabrication / manufacturing equipment and capabilities.
2.
Method of Accomplishment The foregoing objectives were accomplished by observing the manufacturing / fabrication in progress, and discussions with the cognizant vendor personnel.
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7 3.
Findings The vendor is classified as a Specialty Fabrication of metal parts and components.
The vendor is capable of both manual and automatic machining operations. House lifting capacity to six (6) tons.
Unlimited capacity available on as needed basis.
The vendor subcontracts NDE activity in the Radiographic and ultrasonic areas.
Penetrant, magnetic particle, visual inspection and hydrostatic tests are conducted by the vendor's personnel.
The vendor holds valid ASME certificates of Authorization N-2168 and NPT 2164 for class 1, 2, and 3 vessels and piping systems and class 2 and 3 storage tanks and class 1, 2, and 3 MC Vessel parts and Appurtenances and Penetration assemblies.
Class 1, 2, and 3 piping subassemblies and component supports and class CS core support structure parts.
The vendor is capable of all welding activities including manual, semi and automatic.
Heat treat activities is subcontracted to outside vendors.
The vendor is currently processing fourteen (14) commercial nuclear contracts for Penetration Support Guides; and Filters and Strainers.
This represents approximately sixty (60) percent of the total commercial nuclear work load for domestic use.
G.
Exit Interview The inspector met with management representative (denoted in paragraph A) at the conclusion of the inspection.
The inspector summarized the scope and findings of the inspection.
The management representatives had no comment in response to the items discussed by the inspector.
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