ML19318B205
| ML19318B205 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1980 |
| From: | Hunter V, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318B180 | List: |
| References | |
| REF-QA-99900711 99900711-80-1, NUDOCS 8006250126 | |
| Download: ML19318B205 (9) | |
Text
.
O U.S. NUCI. EAR REGULATORY COMMISSION i
0FFICE OF INSPECTION AND ENFORCE S T REGION IV Report No.
99900711/80-01 Program No. 51400 i
Company:
Leckenby Company 2745 lith South West Seattle, Washington 98124 Inspection Conducted: March 17-20, 1980
@Y-M Inspectors:
5py, ;
V. If. Hunter, Contractor Inspector Date ComponentsSection I Vendor Inspection Branch
- , 0Y dA Af00 D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch s /A n
Approved by:
t/J d
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D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch Summary Inspection on March 17-20, 1980 (99900711/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B Crite ia and appli-cable codes and standards; including initial management meeting, QA manual review, and inspection and test control. The inspection involved fifty four (54) inspector hours on site by two (2) inspectors.
Results:
In the three (3) areas inspected, the following deviations were identified.
Deviations: Weld procedure qualifications - Actual number of weld passes not recorded in accordance with AWS DI.1 and Criterion V of Appendix B to 10 CFR 50.
(Notice of Deviations, Item A.2).
Actual amps, volts, and wire travel speeds not recorded in accordance with AWS D1.1 and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.1).
Weld procedure not qualified for material B006250l%
2 thickness welded as required by AWS Dl.1, contract no. 2808-90-EC, and Appendix B to 10 CFR 50 (Notice of Deviation Items A.3 and A.4).
Post weld heat treat-ment not performed on weld test plates in sccordance with AWS D1.1 and Appendix B to 10 CFR 50.
(Notice of Deviation, Item A.5) Production welding performeu with one (1) wire method which was nat qualified in accordance with AWS D1.1 and Appendix B to 10 CFR 50 (Notice or Deviation, Item A.6).
Production Welding - Welding without an approved proce. dure (Notice of Deviation, Item A.17).
Nondestructive Testing (NDT) - One (1) level II MT inspector certified without examination in accordance with SNT-TC-1A and Appendix B to 10 CFR 50 (Notice of Deviation Item A.7).
One (1) unqualified individual performed acceptance UT for < ? Fe material which is contrary to SNT-TC-1A and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.8).
UT examinations not performed after post seld heat treating as required by AWS DI.1 and Appendix B to 10 CFR 50 (Notice of Deviatia, Item A.9) one (1) level I LP inspector conducted and issued an acceptance report for level II work which is contrary to SNT-TC-1A and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.10) one (1) individual certified for level II LP without examination which is contrary to SNT-TC-1A and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.11) two (2) individuals were certified for and conducted level II leak testing without examinations, which is contrary to SNT-TC-1A and Appendix B to 10 CFR 50 (Notice of Deviation, i
Item A.12) one (1) NDT supervisor signed a blank NDT test report and photo-i copied approximately one hundred and two times.
Said test reports were then completed and issued by unknown persons for two (2) years which is contrary j
to SNT-TC-1A and Appendix B to 10 CFR 50 (Notice of Deviation, Item B).
Weld Repairs - Weld repairs and inspections not conducted in accordance with AWS D1.1 and Ap;.endix B to 10 CFR 50 (Notice of Deviation, Item A.13).
Qualltv Assurance Program - QA manual not submitted for approval in accordance with cuscomer contract and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.14) QA program does not provide for written policies, procedures, or instruc-tions as required by Appendix B to 10 CFR 50 (Notice of Deviation, Item C).
Manufacturing - Inspection hold points by passed which is contrary to DOP 614.0 and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.16).
Weld wire travel speeds not documented as required by Appendix B to 10 CFR 50 (Notice of Devia-tion, Item A.18).
Rejected material not identified as required by QCP 7.3. and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.15).
3 DETAILS SECTION A.
Principal Persons Contacted
- B. E. Weeks, Chairman
- R. D. Pittsenbarger, Chief Engineer
- A.
E. Kunzler, President
- P. D. Moore, Quality Assurance Manager
- J. A. Smistad, Production Manager
- J. W. Bowman, Manufacturing Supervisor
- W. Clemens, Quality Assurance Technician H. V. Baldwin, Weld Technician R. A. Harriman, Acting Production Foreman D. S. Haley, Welding Engineer
- Denotes those present at the Exit Enterview meeting.
B.
Initial Management Meeting 1.
Obfectives The objectives of this meeting were to accomplish the following:
To meet the Leckenby Company management and those individuals a.
responsible for the administration of the QA program. Also to establish channels of communications.
b.
To determine the extent of the company's involvement in the commercial nuclear business.
To explain NRC direct inspection program including the Vendor c.
Inspection organization and inspection methods and do,cumentation.
~
2.
Method of Accomplishment The foregoing objectives were accomplished by a meeting on Monday, March 17, 1980. The following is a summary of the meeting:
a.
Attendees were:
Ben Weeks, Chairman of the Board Robert Pittsenbarger, Chief Engineer Phillip D. Moore, Quality Assurance Manager The responsible officers of the Leckenby Company, and D. Whitesell, Chief, Component Section I 1
4 i
V. Huntar, Contractor Inspector Representing the NRC, Office of Inspection and Enforcement, Vendor Inspection Branch.
b.
The NRC organization charts delineating how the Vendor Inspection Branch is structured within the Region, OIE and NRC was distrib-uted and the functional responsibilities were discussed.
How the VIB inspections are conducted, the inspection priorities c.
and frequencies, how the findings are documented, reponses to enforcement items, how proprietary information is handled, the Public Document Room, and the White Book.
d.
The company's manufacturing capabilities, manufacturing activities and its contribution to the nuclear industry, and the types of nuclear components or equipment, the company manufactures, were described by the responsible company's representatives.
e.
The inspectors were conducted on an orientation tour of the Leckenby Offices and Shops.
3.
Results The Leckenby Quality Assurance Manager was itentified as being a.
the company's contact with NRC and all communications and correspondence would be channeled through him.
b.
Leckenby has provided nuclear components to sixteen (16) nuclear customers of which seven (7) are currently being proc.essed in-house. The components includes Reactor sacrificial shield walls, high density poison spent fuel storage racks, " Wagon Wheel" pipe rupture restraints, vibrating equipment and capping machines for consolidating rad-waste into containers, pipe whip restraints, and protective shipping containers for enriched UF cylinders.
6 The nuclear work constitutes approximately fifteen percent (15%)
of the total work load.
c.
The Leckenby Company currently holds an ASME Certificate of Authorization number 14,759, to use the Pressure Vessel U stamp.
It has contracted with the Hartford Steam Boiler Inspection and Insurance company to provide independent third party inspection on an itinerante basis. There was no code work being processed at the time of inspection.
The company made formal application for Certificate of Authori-zation to use the ASME A and PP stamps, on March 8, 1980.
O l
5 I
C.
QA Manual Review 1.
Objectives The objectives of this area of the inspection were to ascertain whether the Leckenby quality assurance program is documented by written policies, procedures and/or instructions and the safety related functions are being performed in accordance with those written policies, procedures, and instructions, in a manner which is consistent with its contract commitments, and the NRC rules and regulations.
2.
Method of Accomolishment The foregoing objectives were accomplished by review of the following:
a.
Review of contract no. 2808-215; and the Design Drawings and Technical Specifications for contracts 2808-215 and 2808-90 to ascertain the quality requireme:ats imposed on Leckenby by the customer.
b.
The Leckenby Quality Assurance Manual, Revision 5 dated 3-7-80 to verify that the program is documented by written policies, procedures or instructions and provides for systems to control the quality activities associated with the design, manufacture, test and inspections of nuclear components, to the extent con-sistent with their importance to safety. Also to ascertain whether the company has expressed a quality assurance policy, and provided the QA staff with sufficient authority to effec-tively achieve its assigned responsibilities.
c.
Review of the organization charts to ascertain whether the QA organization was structured within the Company in a manner which provides the following:
(1) Access to a level of management who has the authority to enforce positive and effective implementation of the QA program within the across the several lines of depart-mental responsibilities and authority.
(2) The QA staff has been provided with organizational indepen-dence and freedom to identify quality problems, to initiate and/or recomend resolution, to verify that corrective actions have been properly Onplemented, and have been vested with authority to stop work until the problem is appropriately dispositioned.
6 d.
Review of the several sections of the QAM to ascertain whether procedures were required, developed, and were available at the point of use, to effectively control the quality activities necessary to design, manufacture, inspect, and test nuclear components, or items, in a manner consistent with the NRC rules and regulations, and contract requirements and the company's commitments.
Discussions with the company's cognizant personnel.
e.
3.
Findings The contract documents specified that the Leckenby Company were a.
to provide a QA program in compliance with Appendix B to 10 CFR 50, and ANSI N45.2.
b.
The documents reviewed demonstrated that the QA staff had access to a level of management which has the authority to effective Laplementation of the QA program, across depart-mental lines of responsibility and authority.
It also has the independence and freedom from pressures of costs and scheduling, to identify quality problems, initiate, or recommend resolution.
There was no evidence that the QA Program was adequately docu-c.
mented by written policies, procedures, or instructions to ensure positive control of all of the safety activities associated with design, manufacture, inspection, and tests. This is a deviation.
(See Notice of Deviation, Item C.)
D.
Design Control 1.
Objectives The objectives of this area of the inspection were to ascertain whether Leckenby had a system for controlling those design activities for which they are responsible, and whether the con-trols were responsive to, and consistent with the NRC rules and regulations, and its contract requirements.
2.
Method of Accomplishment The foregoing objectives were accomplished by:
a Review of Se: tion 3, Design Control, of the QAM.
b.
Review of the latest revisions of the Customers Design Drawings and Technical Specifications for the Sacrificial Shield Wall manufactured by Leckenby under Contract Nos.
2808-215, and Leckenby Fabrication and Assembly drawings for Job Order no. 5758, Revision 8, dated 7/25/75, to verify that the customer quality requirements had been correctly translated to the in-house manufacturing documents.
i
)
7 c.
Review of the Advance Bill of Material for Job No. 5758 to verify that the size, type and grade of materials were in compliance with the Customer's requirements.
d.
Review of Dwg no. 80E1489, dated 2/17/78; Revision 2, dated 12/14/79, for Fuel Storage Racks for Crystal River, Job Order No. 6084, to verify whether the Project Engineer was transi-lating the customers quality requirements into drawings, speci-fications, procedures or instructions in compliance with Appen-dix B to 10 CFR 50.
Discussions with Leckenby's cognizant personnel.
e.
3.
Findings It was verified that the design drawings, design specifications, a.
design calculations or stress analysis and seismic analysis are not included as part of the nuclear customers contract requirements.
b.
It was verified that Leckenby did not have a system documented by written procedures for controlling and documenting the review of the customer's specified quality requirement to ensure that they had been correctly incorporated into those design drawings, bill of materials procedures in compliance with Appendix B to 10 CFR 50.
It was also determined that there was no provision to control inconsistencies in quality requirements of the cus-tomers documents, or deviations from requirements which may be required in order to manufacture the item.
It was verified that although Leckenby does review the customers c.
designs to ascertain that the specified quality requirements are correctly incorporated into the in-house documents, the lack of specific detail procedures to control these quality activities is an example of one instance where the QA program is not documented by written precedures as identified in C.3.c, above.
4.
Comment It was verified that in response to the above finding, Leckenby had prepared a procedure for comment or approval, to provide assurance that customers specified quality requirements are correctly trans-lated into Leckenby drawings, specifications, bill of materials, procedures, instructions, or check list to ensure compliance with all of the customers specified quality requirements, t
The procedure as approved and its implementation will be verified during the next inspection.
8 E.
Control of Special Processes 1.
Objectives The objectives of this area of the inspection were to verify that special processes such as welding and NDE, are controlled in a manner consistent with procedures used by the vendor and that they meet applicable requirements of the contract and NRC rules and regulations.
Also, verify that NDT and welding was being performed by qualified personnel in accordance with approved procedures and the vendor's quality assurance program.
2.
Method of Accomplishment The preceeding objectives were accomplished by:
a.
Review of customer contract No. 2808-90-EC for forty eight (48) type III pipe whip restraints.
b.
Review of the vendors procedure handbook.
Review of Section 11.0 of the customer approved QA manual titled c.
" Test Control."
d.
Review of Section 12.0 of the customer approved QA manual titled
" Control of Measuring and Test Equipment."
e.
Review of Q.C.P. 7.3 f.
Review of weld procedures and their qualifications.
g.
Observed welding of a base assembly identified on Manufacturing Order (MO) No. 6738-3.
h.
Review of Section 9.0 of the QA manual titled " Control of Special Processes."
i.
Observed tack welding of spacer block A as identified et MO No.
6738-21.
J.
Reviewed approximately twenty (20) NDT personnel qualification records.
k.
Interviews with all available personnel.
o *. -
9 3.
Inspection Findings a.
Deviations See Notice of Deviation b.
Unresolved Items None were identified F.
Exit Interview The inspectors met with management representatives (denoted in paragraph A.) at the conclusion of the inspection on March 20, 1980. Management representatives were advised that time did not permit a full review of their QA program implementation. However, the areas covered did disclose twenty (20) significant deviations from commitments which indicates that Leckenby has not implemented an effective QA program that is con-sistent with the requirements of Appendix B to 10 CFR and ANSI N-45.2 as contractually imposed by Leckenby nuclear customers.
The management representatives commented that corrective actions were being made in several areas at the time of this inspection, and further, that Leckenby is fully committed to taking complete corrective actions as necessary to meet the quality requirements of Appendix B to 10 CFR 50 and ANSI N-45.2.
The inspector stated that he would schedule an inspection of Leckenby in 60-90 days to evaluate the progress of the corrective actions.
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