ML19341B958
| ML19341B958 | |
| Person / Time | |
|---|---|
| Issue date: | 10/08/1980 |
| From: | Herr R, Potapovs U, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19341B949 | List: |
| References | |
| REF-QA-99900727 NUDOCS 8102280291 | |
| Download: ML19341B958 (7) | |
Text
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O U. S. NUCI. EAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900727/80-02 Program Number 51400 Company:
Keene Corporation Ray Proof Division 50 Keeler Avenue Norwalk, Connecticut 06556 Inspection Conducted:
August 27-28, 1980
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Inspectors:
r T). E.Whitesep, Chief,ComponentSection1 Date M/ Ads A / nDff0 O
i s-R. Herr, Investigator, Region IV Date Approved by:
V tj1(ky?
/ c - F_. @
U.Potapovs, Chief,VendorIppectionBranch-Date ~
Summary Inspection conducted August 27-28, 1980 (99900727/80-01)
Areas Inspected: The inspection included an Initial Management Meeting, and the review of the vendor's QA program to evaluate whether it is consistent with the requirements 'of Appendix B to 10 CFR 50 and the vendor's contract commit-ments._ Also to ascertain whether the control of welding qualifications are being effectively implemented. The inspection involved 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> by two (2) inspectors.
Results:
In the two areas inspected no deviations or unresolved items were identified in one (1) area; in the remaining area two (2) deviations were identi-fied in the control of Special Processes which do not appear to be consistent with Criterion IX, of Appendix B, or the contract commitments.
(See Notice of Deviation).
N 8102280 N
2 DETAILS A.
Persons Contacted:
- R. Yff, Vice President, Operations G. L. Perkins, Vice President, Manufacturing G. VanDyk, Chief Engineer W. F. Deegan, Purchasing Manager F. A. Olsen, Quality Control Manager Michell Fitzgerald, Engineer
- Denotes those present at the exit meeting.
B.
Initial Management Meeting 1.
Objectives The objectives of this meeting were to accomplish the following:
To meet with the company's management and those persons responsi-a.
ble for the administration of its Quality Assurance program, and establish channels of communications.
b.
To determine the extent of the company's involvement in the nuclear industry, c.
To explain NRC's charter to protect the health and safety of the Public, the Vendor Inspection Branch's goals, and how VIB is structured within NRC, and its inspection methods and documentation.
d.
To inform management of certain alleged deficiencies relating to the rstiod used to qualify welders.
2.
Methods of Accomplishment a.
The above objectives were accomplished in a meeting, conducted August 27, 1980, with the following attendees:
Mr. Robert Yff, Vice President, Operation Mr. Fritz Olsen, Manager, Quality Control (part time) b.
- The NRC inspector explained the objectives of the meeting, the NRC organization and VIB's goals, inspection methods, and how the inspections are documented. Also how responses to findings are to be handled and the Public Document Room.
3 c.
Mr. Yff explained the organization of the Ray Proof Division of Keene Corporation, and described its products and contribution to the nuclear industry.
d.
The NRC investigator explained to Mr. iff in a closed meeting, the allegations received by NRC that the company may be using unqualified welders in its production welding of nuclear items.
The NRC inspector informed Mr. Yff that due to the allegation, the e.
scope of the inspection would focus on the control of its welding, particularly in the area of welder performance qualifications.
3.
Results The company's Vice President, operations, explained that the a.
Keene Corporation, Ray Proof Division's activities were for the design.and manufacture of prefabricated shield walls and doors, primarily for x-ray rooms.
However, they have provided shield doors for five nuclear facilities within the continental limits of the United States and one foreign facility.
Ray Proof Division (RPD) is not a code shop, and the code imposed by its nuclear customer's for welding, has been AWS D1.1-75.
He also explained that the majority of the production personnel were carpenters, and only a small number of welders (3-6) were re-quired in the fabrication of shield doors.
b.
The Vice President expressed his concerns regarding the allega-tion and provided full cooperation in the conduct of that por-tion of the investigation performed within the shop, which required review of QA/QC records and documents, and interviews with personnel who were in a position to contribute necessary information.
c.
The inspector and investigator were conducted on a short orien-tation tour of the facility, where they could observe the activities in progress.
It was observed that the shield doors for WPPS #2 were completed, and partially crated zor shipment.
C.
Quality Assurance Program Evaluation 1.
Objectives k.
4 The objectives of this area of the inspection were to ascertain the following:
Whether the program is documented with written policies, pro-a.
cedures and instructions consistent with NRC rules and regula-tions; b.
Whether tha QA/QC staff have organizational independence and freedom from costs and a.cheduling, to identify quality problems, recommend or initiate corrective action, and to control pro-duction from further processing until quality items are appro-priately dispositioned.
2.
Method of accomplishmert The foregoing objectives were accomplished by the following:
Review of the Quality Assurance Manual (QAM) Revision 2, dated a.
February 1, 1979, to verify that a written statement, signed by the RPD President, was provided, and that the statement estab-lished the RPD policy concerning the design, manufacture, in-spection and test activities to ensur: quality products; and assigned responsibilities and authority to perform, verify, and to enforce, proper performance and verification of those activities.
b.
Review of the RPD organizational charts to verify that the QA/QC staff are structured with the RPD organization in a manner which provides the QA/QC staff independence and freedom from cost and scheduling respunsibilities, and provides them access to a level of management who has the authority to enforce proper implementation of the QA program across the several depart-mental lines of responsibilities and authority within RPD.
c.
Discussion with cognizant personnel.
3.
Findings The review of the QAM demonstrated that it addresses all eighteen a.
(18) criteria of Appendix B to 10 CFR 50, and, if properly imple-
-mented, would provide reasonable assurance that the quality level prescribed for the finished product, would be achieved. Time did not permit an in-depth verification of the implementation of various program elements.
b.
During the QAM review, no deviations or unresolved items were noted.
)
+
5 Performance Qualifications) d Control of_Special Processes (Wel ers D.
were to ascertain Objectives of this area of the inspection conducted and 1
alifications areith NRC rules and The objectives whether welders performance qua manner which is consistent wtract c controlled in regulations, and the nuclear con Method of Accomplishment lished as follows:
2 The foregoing objectives were accomp ertain whether a system Review of Section IX, of the QAM to ascs are to be co how welder's performance has been provided which prescribes a.
i qualifications and certificat on N2467, Part - Door Leaf b
h door Review of Shop Traveler for Job Num er whether the Heat number of t efied and No. A126, to ascertain sequences for welding b.
material was identified, veri used, and whether thewelds we Also, whether the operationwelding proced and date.
identified the welders performing the tack en 9 qualification records, and 9
Review of weld procedure (WPS) 12-1-tion records us i
welders performance qualif ca ther e,ognizant c.
welders, weld foreman, and o the Discussions with the d.
personnel.
s with the responsible Findings The documents reviewed and discussionimplementation o 3
h welders per-personnel, demonstrated that t ein controlling thewith criterion I a.
activities are not effectiveformance qualifications liance h
of Appendix B to 10 CFR 50, t eSection IX of th n a L * ~
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weld test..samni a The QAM requires (1)
-i sdadweld ng auditors.
N(u are not re
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p %sp
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Ws 6
(2) The QAM requires all welding to be performed by welders who have been qualified in accordance with AWSD1.1-75.
- However, two welders identified on the traveler reviewed as having made certain tack and production welds, denied that they had welded the test coupons used for their qualification tests.
See NRC investigation report 99900727/80-01).
b.
The foregoing are considered to be deviations.
(See Notice of Deviations, items A & B.)
E.
10 CFR Part 21 Inspection 1.
Objectives The objectives of this area of the inspection were to ascertain whether the requirements of Title 10 of the Code of Federal Regulations Part 21, had been contractually imposed by any nuclear customers.
2.
Method of Accomplishment The foregoing objectives were accomplished as follows:
a.
Review of PO No. 10407-13-AM-076 dated March 9, 1979 for a Quality Class Q Missile Resistent Doors; paragraph 2.14.3.
b.
Review of PO S-0593 dated October 25, 1979, Specification No.
311.2500, Paragraph 1D.4.
c.
Review of Personnel Bulletin Boards (4) within the Ray Proof facilities.
d.
Discussion with Ray Proof Vice President, Operation.
-3.
Findings a.
There was no evidence available that Public Law 93-438, Section 206, and/or 10 CFR Part 21, had been posted on any bulletin board in the plant, as required by the law, and the regulation.
There was no evidence that the vendor had developed procedures for evalu-ating the safety significance and reporting identified " defects" as defined Sy the regulation.
b.
See Notice of Violation.
7 E.
Comments 1.
Management's attention was directed to the fact that th: RPD QA pro-gram does not provide measures for the control of welder's identifi-cation stamps to prevent early reissue of stamps which formerly identi-fied terminated welders. Management agreed that this is good practice, and stated that such measures would be provided.
2.
In the review of AWSD.1.1-75, Section 5.3, Velders, Welding Operations, and Tackers, it is noted that the welder's performance must be quali-fied for each welding process he uses in production. However, unlike Section IX for the ASME, AWS gives the Engineer the option of accepting evidence of a previous qualification of the welder. Whether or not the two welders who denied welding the test coupon used by the company to qualify them, had ever been qualified previously on another job, was not pursued during the investigation.
.