ML19318B841
| ML19318B841 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318B834 | List: |
| References | |
| REF-QA-99900287 NUDOCS 8006300157 | |
| Download: ML19318B841 (3) | |
Text
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O TRW Mission Manufacturing Company 99900287/80-01 NOTICE OF DEVIATION 3ased on the results of an.\\RC inspection conducted on February 25-28, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
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 accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Deviations from these requirements are as follows:
A.
Paragraph 13.2 in Section 13.0 of the QA Manual states in part with respect to Material Discrepancy Reports (MDRs), "After preparing an MDR the Inspector shall:
. 13.2.2 Record the MDR number in the Shop Traveler at the appropriate operation.
" Paragraph 13.3 states, "The Material Review Board shall consist of TRW Mission Manufacturing Company's Quality Assurance Representative, a TRW Mission Manufacturing Company Project Valve Engineering Representative and the customer's representative if required." Sub paragraph 13.3.1 states, "The Material Review Board will make disposition on discrepant material, parts, services and components.
There shall be no Code deviations pe citted."
Contrary to the above, the following was noted with respect to MDR No. 041918, which was issued in respect to a three (3) inch valve body, (W S/N 8661:
1.
The MDR number had not been recorded in the Shop Traveler.
2.
The MDR was dispositioned by a Quality Control Representative on July 3, 1979, and not by a Material Review Board consisting of representatives from Quality Assurance and Project Valve Engineering.
B.
Paragraph 13.2, sub-paragraph 13.2.3, in Section 13.0 of the QA Manual states in part, " Tie the hard copy to the part or to one of several like parts and mark the MDR number on all the parts with a marking material coa.patible with size, material condition and cleaning requirements of the parts..." Sub-paragraph 13.2.5 states, " Move properly tagged and marked, rejected material or parts to a Holding Area which shall be p oesco
TRW Mission Manufacturing Company 2
designated by Quality Assurance and shall be marked off and clearly identified as a Holding Area."
Paragraph 13.5 states, "After final disposition has been made, the MDR shall be presented to the Inspection Department Foreman who will cause the dispositioned hard copy portion of this form to be attached to that section addressed in 13.2.3.
The Inspection Department will move the discrepant material and associated shop travelers from the rejected material area to a repair, back in process or scrap area as required by the disposition."
Contrary to the above, the following was noted with respect to 38 pin retainers that were observed in the Quality Assurance Holding Area on Feb ruary 27, 1980, and for which it was established MDR No. 050262 had been issued relative to thread damage:
1.
The hard copy of the MDR was not attached to one of the parts and the MDR number had not been marked on any of the parts.
2.
The dispositioned hard copy of the MDR was not attached to a part and the parts had not been moved, although a disposition to rework was made on December 3, 1979.
C.
Paragraph 17.7 in Section 17.0 of the QA Manual states, " Pressure gages used to determine actual test pressure are calibrated in accordance with paragraph 8.2 of this Manual. The Serial Number of gages used are recorded on the ' Valve Inspection and Test Report'."
l Contrary to the above, pressure gage serial numbers were not recorded on the Valve Inspection and Test Report for those gages used in the hydrostatic pressure test of Valve Serial Nos.
L6250, L6251, and L6252.
D.
Paragraph 1.0.6.15, sub-paragraph 2, in Gilbert Associates Conformed Specification SP-521-01-4549-00, Revision 1, states in part with respect to vendor QA program requirements, "The procedure shall adequately describe the following:
. c.. guidelines for determining the need for corrective action."
Contrary to the above, the TRW Mission QA program (QA Manual or corrective action procedure QCP 100, Revision 0) did not describe guidelines for determining corrective action need.
(See Details, C.3.a (4))
E.
Paragraph 1.4.7 in Section 1.0 of the QA Manual states, " Manufacturing shall be responsible for explicitly following all Shop Travelers and other work defining documents."
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Contrary to the above, Manufacturing did not explicitly follow Shop Travelers for six (6) valves ( S/Nos. K-7166 through K-7171) with respect to packaging, as evidenced by the valves being observed unpack-aged on February 27, 1980;. although signed off by the operator in the respective travelers as having been packaged on December 26-28, 1979, and with no subsequent traveler instruction or cther work defining document issued that account for any later unpackaging.
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