ML19309F319
| ML19309F319 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309F295 | List: |
| References | |
| REF-QA-99900338 99900338-79-1, NUDOCS 8004290203 | |
| Download: ML19309F319 (13) | |
Text
_ _ _ _ _ _ _ - _ _
O Marvin Engineering Co., Inc.
Docket No. 99900388/79-01 NOTICE OF DEVIATION Based on the results of a special NRC inspection conducted on September 18-21 1979, it appears that certain of your quality assurance activities were not conducted in accordance with NRC requirements.
1.
Criterion I of Appendix B to 10 CFR 50 states in part,
. The persons and organizations performing quality assurance functions shall have suf-ficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. Such persons and organizations performing quality assurance functions shall report to a management level such that this required author-ity and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided...."
The Statement of Policy in Marvin Engineering Co., Inc. (MEC) Quality Assurance Manual ASME Section VIII-Div 1 and Pressure Piping Section I, Revision 0, (hereafter referred to as Quality Manual A) states in part,
. The manual will meet the requirements of 10 CFR 50 Appendix B.
The Statement of Policy in MEC Quality Control Manual No. 7, Revision 0, (hereafter referred to as Quality Manual B) states in part, "This manual sets forth a Quality Control system in ccnformance with 10 CFR 50 Appendix B amended 9-11-71.
The manual will meet the requirements of 10 CFR 50 Appendix B...."
Contrary to the above, the Quality Control system contained in Quality Manuals A and B is not in compliance with Criterion I of Appendix B to 10 CFR 50 requirements relative to QA personnel organizational freedom and independence from cost and schedule, in that:
1.
Nuclear Division QA personnel report to the Nuclear Program Manager and not the MEC QA Manager.
2.
The Quality Manuals vest specific responsibility for the monitoring and administration of the nuclear QA program in the Nuclear Program manager.
3.
This individual has both overall responsibility for all nuclear product activities, including manufacturing and production con-trol, and is personally fulfilling functions such as marketing contract administration, process and methods engineering and quality control engineering.
(See Details Section, Paragraph C.3.a.)
8004290203 m-m m
2 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 accom-plished in accordance with these instruction, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quanti-tative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Deviations from
,l these requirec..sts are as follows:
2.
Paragraph 3, sub paragraph 3.5, in GE Purchase Specification 22A5517 Revision 3, which is applicable to MEC Job No. 2480A, states in part, "Both welders and welding procedures shall be qualified in accordance i
l with Section IX of the ASFE Boiler and Pressel Vessel Code.
Paragraph 1.0, sub paragraph 1.1, on page 50 of Quality Manual A and on page 51 of Quality Manual B states, "All welding procedures and welder qualifications shall be carried out in accordance with AS?E Code,Section IX, Welding Procedure and Qualification and ASME Code Section III requirements."
Contrary to the above, welding procedure specifications ME-WP-2 Revision 0 and 1, and ME-WP-4 Revision 0 were not carried out in accordance with l
Section IX of the ASME Code, in that they did not either specify nor were they qualified for a required solution annealing heat treatment.
(See l
Details, Section, paragraph D.3.a.(1))
3.
Paragraph 3.0, sub paragraph 3.8, on page 51 of Quality Manual A states, l
"Marvin Engineering Co. shall only utilize qualified Welders o.r weld operators to meet ASME Code or customer requirements."
l l
Contrary to the above, MEC utilized other than qualified welders on Job No.
(
1805, in that twenty-eight (28) examples of the use of an unqualified welder were identified.
(See Details Section, paragraph D.3.a.(2))
4.
Paragraph 1.0, sub paragraph 1.1, on page 50 of Quality Manual A and on l
page 51 of Quality Manual B states, "All welding procedures and welder qualifications shall be carried out in accordance with ASME Code,Section IX, l
l Welding Procedure and Qualification and ASME Code Section III requirements."
Section IX of the ASME Code, Article 1, Sub-Article QW-103, states, "Each manufacturer or contractor is responsible for the welding done by his organization and shall conduct the tests required in this Section to qualify the welding procedures he uses in the construction of weldments built under this Code, and the performance of welders and welding operators who apply these procedures.
Each manufacturer, or contractor, shall maintain a record of the results obtained in welding procedure and welder and welding operator performance
3 qualifications. These records shall be certified by the manufacturer, or contractor, and shall be accessible to the Authorized Inspector. Refer to recommended forms in QW-480."
Contrary to the above, it could not be verified from the MEC records of welder performance qualification tests, although certified to be correct, that all welder qualifications had been carried out in accordance with the test requirements of Section IX of the ASME Code, in that:
1.
A single test plate prepared by one (1) welder was apparently used for the radiographic qualification of two (2) welders.
2.
The QW-484 Form (ASME Manufacturer's Record of Welder or Welding Operator Qualification Tests) for a welder, referenced a Laboratory Test No.
that could not either be located, or, established to exist during the inspection.
3.
The QW-484 Form for another welder, dated October 31, 1978, referenced a Labchatory Test No. that was not accomplished until August 27, 1979.
(See Details Section, paragraph D.3.a(3)).
5.
Paragraph 3.0, sub-paragraph 3.1, on page 53 of Quality Manual A and on page 54 of Quality Manual B states in part with respect to issuance of weld materials, " Chit form (Fig. 23) shall be filled out in its entirety by person making issue and welder.
This form is maintained daily per issue and used for weld material control, traceable to specific customer job."
Paragraph 5.0, sub paragraph 5.1, on page 54 of Quality Manual A and on page 55 of Quality Manual B states in part, It shall be the Inspector's responsibility to monitor chit forms.
. daily for conformance Contrary to the above:
1.
Welders daily chit forms were not used for the purpose of weld material control on Job No. 1805, as evidenced by observation by the NRC Inspec-tors on September 19, 1979, of two chits (from a total of only four that could be located during this inspection for the entire contract),
which were identified with Job No. 1805 and indicated improper welding materials had been issued, i.e. the chits showed 1/16 inch diameter Type 5356 aluminum alloy wire had been issued for use in fabrication of a contract, which involved welding of only carbon and austenitic stain-less steel materials.
2.
Neither were welder daily chit forms being filled out in their entirety, nor was monitoring being performed on a daily basis by the Inspector.
(See Details Section, paragraph D.3.a.(4))
~
4 i
6.
Paragraph 1.0, sub-paragraph 1.1, on page 23 of Quality Manual B states, "All incoming material shall be received by Material Control Specialist.
He shall initiate a Lot Ticket (Fig.15) and route it to Inspection to be processed by the Receiving Inspector to determine acceptance or rejection of incoming material per Marvin Engineering Co. Purchase Order."
Contrary to the above, 0.045 inch diameter SFA 5.-9 ER308L wire, Heat No.
N-5131, was observed in production application on Job No. 2480A, M.0. No.
543, for which the acceptablity had not been determined by FEC.
(See Details Section, paragraph D.3.a(5))
7.
Paragraph 4.7, sub paragraph 4.7.2, in GE Purchase Specification 22A5517 Revision 3, which is applicable to MEC Job No. 2480A, states in part, "All welding... shall be performed in accordance with approved detailed written welding procedures. Welding procedures shall contain all essential and non-essential variables defined in ASME Section IX...."
Paragraph 5.0, sub paragraph 5.1, on page 55 of Quality Manual B states in part, " Inspection personnel shall continuously monitor... all welding i
areas for any nonconformance to weld procedure and ASME Code and customer requirements.
Paragraph 6.0, sub paragraph 6.1 on page 56 of Quality Manual B states in part, "... Any welding being performed found to be noncomforming shall be stopped immediately."
Contrary to the above, welding areas were neither continuously monitored for any nonconformance to weld procedure, nor was welding stopped immediately when found to be nonconforming, as evidenced by.
a.
Welding was observed being performed on September 20, 1979, on Job No.
2480A, M.0. No. 543, Operation No. 570, utilizing 1/16 inch diameter, SFA 5.9 ER308L filler wire, Heat No. 7-11635, when the applicable WPS, ME-WP-2 Revision 1, required the use of 3/32 inch diameter SFA 5.9 E2308 filler wire.
b.
WPS ME-WP-2 Revision I requjres control of interpass temperature in welding to a maximum of 350 F.
The welder performing the operation described in a. above, W-9, was not equipped to measure weld interpass temperatures, until after the NRC inspector had questioned the absence of temperature measurement capability.
c.
WPS ME-WP-2 Revision 1 requires the use of Argon backing gas during all welding operations. Final welding was being performed, however, in the operation described in a. above, without the use of Argon backing gas.
Welding was not stopped after the above obr.ervations of nonconformances
?
to the weld procedure.
_... _ _. ~. _ _. _..
5 8.
Paragraph 6.0, sub-paragraph 6.1, on page 55 of Quality Manual A and on page 56 of Quality Manual B sMtes in part, "... The Nuclear Program Manager shall prepare a report using form (Fig. 33) and any other additional information. He shall review his findings of recurring nonconformance.
A report of this review shall be given to the President, Manufacturing Manager and Engineering Manager quarterly, monthly if need be, in order to maintain a trend analysis of weld material issue and conditioning, storage, welding procedures, welders and Marvin Engineering Co. Quality Assurance Program."
Contrary to the above, no review reports were made available to the NRC inspector to confirm that the committed trend analysis of the welding program was being maintained.
(See Details Section, paragraph D.3.a.(7))
9.
Paragraph 1.0, sub paragraph 1.1, on page 45 of Quality Manual A states,
" Chief Inspector is responsible for the issuance of all stamps used for:
1.
Acceptance or rejection 2.
Nondestructive examination stamp 3.
Welder's stamp 4. Pressure testing stamp 5. Material Review Board stamp" Paragraph 2.0 on page 45 of Quality Manual A states, " Chief Inspector will maintain a stamp control card containing all information shown (Figs. 26 and 27). Anv person-issued a stamp by the Chief Inspector shall consider the use of that stamp to be as binding as his signature and under no circumstances shall the stamp be loaned to another person. All stamps turned in or returned will be placed in bond for six months before reissue can be authorized.
If a stamp is reported lost, the number shall be placed in bond for six months."
Contrary to the above:
1.
The Certificate of Conformance supplied to the customer for Job No. 1805, Fuel Grapple Serial No. 6-612-988, was signed by the Chief Inspector (James E. Richardson) on January 22, 1979, and stamped with a No. 23 stamp. The applicable stamp control card, which was maintained by the MEC Quality Assurance Manager (Robert Paul) and not by the Chief Inspector as required by Quality Manual A, showed that the No. 23 stamp was issued to an inspector named "Earnie Odum" on March 10, 1978.
The stamp control card indicated this individual was still the assigned holder of this stamp as of this inspection.
2.
The Certificate of Conformance supplied to the customer for Job No. 1805, Fuel Grapple Serial No. 6-612-984, was signed by the Chief Inspector (James E. Richardson) on February 15, 1979, and stamped with both a No. 23 and No. 32 stamp. The applicable stamp control card showed that the No. 32 stamp was issued to the Chief Inspector, James E.
Richardson, on February 7, 1979.
(See Details Section, paragraph E.3.a.
(1))
6 10.
Paragraph 3.0 on page 24 of Quality Manual A states, "The Manufacturing Order (Fig. 18) is a detailed operational information sheet and inspection log describing a sequence of operation necessa.ry to manufacture and to inspect detail parts and assemblies.
It defines manufacturing operations, welding procedure, NDE procedures, testing, outside process and Authorized Inspector or customer hold points. The manufacturing order authorizes work to be performed by the manufacturing departments."
Contrary to the above, work required to build five (5) of the six (6)
Job Vo. 1805 fuel grapples was performed without being authorized by a manufacturing order:
i.e.,
the total manufacturing work order (M.O.)
release for Job No. 1805, M.0. Nos. 436 through 464, was sufficient to build only one (1) of the six (6) required and shipped fuel grapples.
11.
Paragraph 2.0 on page 32 of Quality Manual A addresses requirements which must be satisfied in the final inspection function.
Sub paragraph 2.1 states in part, " Items will be presented to the Inspector with Manufacturing Order which identifies them by drawing number and revision, and Marvin Engineering Co. job number.
Sub paragraph 2.2 states in part, "A review of the Manufacturing Order... to establish that the requirements of Quality Assurance procedures and in-process inspection instructions have been carried out and evidenced by inspection stamps. This includes material verification, special process verification,... authorized weld stamps,... completion of all operations.
." Sub paragraph 2.3 states in part, "The results of the inspection must be completely documented in terms of quantity accepted, inspection stamps and dates for all indicated characteristics.
Contrary to the above:
1.
Final inspection was not performed on Job No. 1805 with respect to compliance with Quality Assurance procedures and in process inspection instructions, in that:
I a.
Items could not have been presented with Manufacturing Orders for five-sixths (5/6) of the work, since Manufacturing Orders issued for this contract would account for the fabrication of only one (1) of the six (6) required and shipped fuel grapples.
l b.
Review of itcas manufactured without use of Manufacturing Orders could conscquently not have been accomplished.
7 Examination of the issued Manufacturing Orders for this contract c.
(Manufacturing Order Nos. 436 through 464) showed that they had been accepted at the final inspection operation by Stamp No. 23 (See Item 9, above), without dating or indicating quantity accepted, although there was no evidence of material verification or use of authorized weld stamps and sign-off of operations was also incomplete.
12.
Paragraph 1.0, sub paragraph 1.1, on page 28 of Quality Manual A states in part, " Chief Inspector is responsible for personnel to perform in process inspection and final inspection.
In process inspection shall be accomplished at all points specified on the manufacturing work order, as well as surveillance of all manufacturing operations at all times...."
Contrary to the above:
Performance of required liquid penetrant inspections on Job No. 18r/;.,
a.
1 Fuel Grapple Serial No. 6-612-989, could not be verified, in that the Certified Test Reports of Non-Destructive Examination for this assembly showed an examination date on which the employee performing the examinations was indicated by MEC personnel attendance records to have not been at work.
b.
In process inspection with respect to liquid penetrant examination was not accomplished on Job No. 1805 at all points spo. Cied on the manufacturing work order, as evidenced by all Certified Test Reports of Non-Destructive Examination for Job No. 1805 referencing Operation No. 10 as the applicable Operation No.
This Operation No. was utilized on all MEC manufacturing work orders for Job No. 1805 to draw materials, items and sub-assemblies from stores.
(See Details Section, paragraph E.
3.a.(4))
13.
Job No. 1805 required the use of MEC Procedure, ME-12N Revision 0, for the performance of designated liquid penetrant examinations.
Paragraph 4.2 in MEC Procedure, ME-12N Revision 0, states in part with respect to penetrant materials, "... The residual amount of total sulfur and halogens shall not exceed one percent by weight. Manufacturer's Certi-fication that the materials meet the requirement shall be kept on file at Marvin Engineering and shall be available to the customer upon request."
Paragraph 6.10, sub paragraph 6, in MEC Procedure, ME-12N Revision 0, states, "A method technique data sheet shall be made for each penetrant testing technique." Paragraph 6.10, sub paragraph 8, in MEC Procedure, ME-12N Revision 0, states, "A copy of test report, technique sheet shall be included in final data records."
9
8 Contrary to the above, certain of the method technique data sheets applicable to the liquid penetrant examination of Job No. 1805, Fuel Grapple Serial Nos. 6-612-984 through 6-612-989, showed the use of water washable penetrant material, for which no Manufacturer's Certification was on file.
(See Details Section, paragraph E.3.a.(5))
14.
Quality Manuals A and B, paragraph 3.2 on pages 25 and 27 respectively, states in part, "The manufacturing order body shall describe.
. operation description,... procedures as specified in the contract to insure completion of that particular operation.
Contrary to the above, the M.0. bodies did not describe operations and pro-cedures as specified in the contract relative to Job No. 1805, to insure completion of the liquid penetrant inspection operation; i.e.,
the following General Electric Company (GE) drawings require liquid penetrant inspection:
105D6421; 105D5850; 166B9100, and 769E520. The liquid penetrant inspection requirements were not included in the bodies of the following two (2) M.O.s:
M.O.437 (Drawing No. 769E520), and M.0. 439 (Drawing No. 105D5850).
15.
Quality Manuals A and B, paragraph 3.0 on pages 24 and 26 respectively, states in part, "The Manufacturing Order (M.O.)... is a detailed operational information sheet and inspection log describing a sequence of operation necessary to manuf acture and to inspect detail parts and assemblies.
It defines manufacturing operations, welding procedure, NDE procedures.
Paragraph 3.2 on pages 25 and 27 respectively, states in part, "The M0 body shall describe... procedures... including revision letters of procedures, in ef fect at time of preparation."
Contrary to the above, procedures and/or revisions for welding and non-destructive examinations are not defined on numerous M0s relative to the following customer (General Electric Company) contracts:
MEC Job No.
GE Purchase Order 1805 (Fuel Grapples) 282-KF295 2480A (Feedwater Spargers and Thermal 205-AM191 Sleeve Assemblies)
(See Details Section, paragraph E.3.b.(2))
16.
Quality Manual A page 50, paragraph 1.2 states in part, "The Engineering Department shall specify the welding procedure as required by the Code and l
l
. _ - ~
l 9
~
l Customer specifications.
Weld procedure shall be reviewed by the
.. (Customer, if required) before any work is performed."
Contrary to the above, the Engineering Department did not specify the correct welding procedure required by Customer specifications. Operations 50 and 90 on M.0. 447 of Job No. 1805 state, " Weld per ME-WP-4."
ME-WP-4 is for use on stainless steel. The Customer specification as shown on the drawing requires the use of weld procedures qualified for use on carbon steel. The only weld procedure at MEC identified by the NRC inspectors to be qualified for carbon steel is ME-WP-7.
It should be further noted, there was no evi-dence of review by the customer of ME-WP-7.
(See Details Section, paragraph E.3.b.(3))
~
17.
Quality Manual A page 24, paragraph 3.0 states in part,
... The manu-facturing Order (M.O.) authorizes work to be performed by the manufacturing i
departments." Subparagraph 3.1 states in part, "A sequential number f
is assigned to each manufac~ turi'ng order. A manufacturing order numerical j
control log is maintained by the Planner.
In the heading of the M.0. is a release date which signifies the date on which the M.0. is released so that manufacturing may proceed.
Contrary to the above, work was performed on Job No. 1805 by manufacturing departments without being authorized by an M.0. as evidenced by the Release Date of 10/19/78 on M.O.s 436 through 464 (except 461 which is not dated),
and the first operation on seven (7) M.O.s had been signed off as much as five (5) weeks earlier than the 10/19/78 release date.
(See Details Section, paragraph E.3.b.(4))
18.
Quality Manual A page 30, paragraph 7.0 states in part, ".
. It is the responsibility of the In-Process Inspector... to see that Manufacturing Order is completed, dated and signed off by manufacturing personnel (after each operation and all inspection operations showing affixed stamp and date)." Page 32, paragraph 1.0 states in part, "... Inspector shall record his acceptance stamp and date on manufacturing order to show inspection was performed." Page 26, subparagraph 3.5 states in part, "Upon completion of manufacturing cycle, the Manufacturing Foreman.... shall return completed M.O. to Production Ccatrol. The Planner shall check M.0.
for dates, sign offs and inspection acceptance stamp...."
Quality Manual B is identical except the above paragraphs are on pages 32, 34 and 38, respectively.
Contrary to the above, the inspectors have not and are not affixing stamps i
or dates after all inspection operations. The in process inspector has not and is not seeing that the M.0. is dated and signed off by manufacturing personnel after completion of operations, and that all inspection operations show affixed stamp and date. The Planner did not check completed M.O.s for dates, sign offs and inspection acceptance stamps.
(See Details Section, paragraph E.3.b.(5))
l i
1 10 i
- 19. Quality Manual A page 32, paragraph 1.0 states in part, "The final inspection function shall satisfy... the verification and/or establishment of adequate documentatior to provide objective evidence that Marvin Engineering Co. (MEC) inspection... has been accomplished...." Paragraph 2.2 states in part, "A review of the Manufacturing Order.
. to establish that the requirements of Quality Assurance procedures and in process inspection instructions have been carried out and evidenced by inspection stamps. This includes... completion of all operations...."
Contrary to the above, the verification and/or establishment of adequate documentation to provide objective evidence that MEC has accomplished all manufacturing, inspection, examination, and test operations, has not i
i been performed for Job No. 1805, Fuel Grapples. Documentation is incorrect l
as evidenced by numerous anomalies throughout; i.e, wrong dates, incorrect spelling of names, dates showing withdrawal of components from stores for use on the final assembly before those components were manufactured, lack of material identity, the use of an inspection stamp which can be attributed to at least three (3) individuals, etc.
(See Details Section, paragraph E.3.b.(6) 20.
Quality Manual B page 4, paragraph 2.0 states in part, "The Quality Control Engineer... shall... conduct a comprehensive review of the Customer Contract... to determine all Required data and documentation requirements.
Page 48 paragraph 2.2, states in part, "... Process Engineer shall assist i
in close collaboration with Nuclear Program Manager in the development l
of various procedures and tests to meet code requirements and customer requirements, procedure and test will be approved by... customer, prior to its intended use, whenever... contractual agreement deems it l
necessary."
General Electric Company Purchase Order 205-AM191, Note 8 for Job No. 2480A states in part, "All welds (including backside of all full penetration welds) are to be visually inspected using direct sight, mirrors, borescope or other method approved by buyer.... Visual and/or RT inspection procedures to be supplied by vendor and approved by buyer prior to use."
Contrary to the above, MEC has not developed or submitted for approval, a visual or radiographic inspection procedure, although numerous welds have been made on Job 2480A, Feedwater Spargers.
21.
Quality Manual B page 53, paragraph 7.0 states, " Nuclear Program Manager shall be responsible to route approved welding procedures to Production Control, Manufacturing, Inspection and Engineering Departments.
Procedure shall be kept in book form by various departments. Current welding
11 procedures to be located in the welding area where the activity is being performed is the responsibility of Production Control Planner."
Contrary to the above, a current welding procedure, ME-WP-2 Revision 1, observed as applicable for in process welding being performed on Job No. 2480A, was not in the welding area and had to be retrieved from the office. This welding procedure was specified by operations 80, 100, 470, 490 and 550 on M.O.543.
22.
Quality Manuals A and B, pages 51 and 52 respectively, paragraph 4.1 state in part, "Each qualified welder will be assigned a number and an identification stamp by the Chief Inspector.
Pages 32 and 34 respectively, paragraph 2.2 states in part, "A review of the Manufacturing Order.
. to establish that the requirements of Quality Assurance procedures.
. have been carried out and evidenced by inspection stamp. This includes (the use of)... authorized weld
- stamps, Contrary to the above, welder identification stamps have not been issued thus never used on any of the jobs reviewed by the inspectors.
As a result, welder identity could not be ascertained relative to a particular welder on Job No.1349. Operations 480, 500, and 530 on M.0. 480 required welding per ME-WP-2, revision 1.
Each of those operations were signed off with a capital letter Q.
The Welder Stamp log shows two (2) welders whose names have the letter Q: Quyn M. Do, and Quan Thanh Hoang.
Discussion with the manufacturing supervisor failed to identify Q.
23.
Quality Manual B pages 34 and 35, subparagraphs 2.2 and 2.3 state in part, j
. A review of the Manufacturing Order... to establish that the in process inspection instructions have been carried out and evidenced by inspection stamps. This includes special process verification, x-ray, Penetrant,
. completion of all operations.
The results of the in ection must be completely documented in terms of quantity inspected Contrary to the above, the required liquid penetrant (LP) examinations of certain root passes, as specified by certain operations on M0543 for Job No. 2480A, were not performed in their entirety in one case, and in another, the quantity is unknown as it was not recorded. Subsequent operations specified completion of the welds. The M.0. shows that these were completed thus precluding the possibility of LP examination being performed.
It should be further noted that the M.0. showed LP examination of the root passes being performed on the unknown quantity before the root passes were deposited. Certain operations for LP of completed welds were not performed in their entirety.
(See Details Section, paragraph E.3.b.[10))
12
- 24. Quality Manual A page 24, paragraph 3.0 states in part, "The Manufacturing Order... defines... customer hold points." Page 26, paragraph 3.3 states in part, ".
. In cases where customer inspection is required, the Planner shall arrange for the customer representative to select his man '
datory hold points and insert them in the sequence of the Manufacturing Order." Page 29, paragraph 5.0 states in part,
... It is the In-Process Inspector's responsibility to see that hold points or inspection points are not by passed." Page 33, paragraph 2.6 states in part, " Documents will be further reviewed by the Inspector for the following:
. Acceptance by Customer... as required for each detail." Page 49, paragraph 8.0 states in part,
... Customer witness points shall be provided as re-quired by individual contracts."
Quality Manual B states the same as abave, except the page numbers are 26, 28, 31, 35 and 50, respectively.
General Electric Company purchase order 205-AM191, Note 5 for Job No.
2480A states.
" Quality Control notification points identified as utility customer / buyer notification points require (3) regular working days ad-I vance notice prior to performance of work on tests specified."
Contrary to the above:
I 1.
Job No. 1349 contained eight (8) Customer Verification Points (as shown cn the following M.O.s and operation numbers) on which there was no evidence of customer verification or waiver, and manufacturing proceeded to continue; M.0. 478, operations 60 and 80; M.0. 480, opera-tions 90, 110, 600, 610, 620, and 640.
2.
Job No. 2480A contains three (3) operations (70, 90, and 560) on M.0.
543, in which the first two (2) are identified as " Customer Notifi-i
(
cation Points" and the last one is identified as a "GE Source Insp.
Visual Req'd."
There is no evidence on the M.0. to indicate customers verification or waiver for operation 70, and manufacturing proceeded to continue.
It should be further noted that at the time the customer representative verified operation 560, the preceeding fourteen (14) operations had not been stamped, signed or dated by MEC manufacturing l
and inspection personnel.
- 25. Quality Manual A and B, paragraph 6.0, pages 35 and 37 respectively, states, " Nuclear Program Manager shall be responsible for submittal of certification of conformance with his signature to customer whenever required."
Contrary to the above, certifications of conformance for Job No. 1805 were not signed by the Nuclear Program Manager (R. Barnack), but by the Chief Inspector (J. E. Richardson).
13 26.
Quality Manual B, page 31, paragraph 4.1 states, "The In-Process Inspector shall be responsible to verify that material or components being drawn from storage area by production manufacturing have retained their identifi-cation by heat number or detail number at all times."
Contrary to the above, five (5) Elbow Assemblies, welded to a Feedwater Sparger, Job 2480A, were observed to be unidentified because of both illegible markings and obliteration of markings.
In addition, identi-fication could not be verified because MEC did not record this information or, the back side of the M.0.
27.
Quality Manuals A and B, paragraph 8.0, pages 23 and 25 respectively, state in part, ".
. Material Control Specialist shall issue material to Manufacturing. Material shall be verified by In-Process Inspector at the time of issue to Manufacturing and recorded on the back side l
of Manufacturing work order, dated and stamped by Inspection.
Contrary to the above, material identification has not been verified and recorded, and dated and stamped on the back side of numerous manu-facturing work orders. Job No. 1805 (Fuel Grapples),
M.O.s 436 thru 464, have 31 inspection verification of material operations, after draw-ing material from stores, and none were recorded.
i Job No. 1349 (Feedwater Spargers) M.O.s 471, 473 thru 480, has 15 " Draw Material From Stores" operations, with 13 " Inspect Material" operations.
l Of the 13, fcur (4) were not recorded.
Job No. 2480A (Feedwater Spargers), M.O.543 has five (5) " Inspect-Verify-Record" operations in which material had been drawn from stores and the material identification had not been recorded.
Note:
1.
Quality Manual A is the applicable manual for MEC Job No.s 1805 and 1349.
2.
Quality Manual B is the applicable manual for MEC Job No. 2480A.