ML20008D985

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QA Program Insp Rept 99900243/80-01 on 800825-29. Noncompliance Noted:Annual Corporate & Division Audits Not Performed as Required by QA Manual
ML20008D985
Person / Time
Issue date: 09/19/1980
From: Sutton J, Whitesell D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20008D981 List:
References
REF-QA-99900243 NUDOCS 8010240022
Download: ML20008D985 (8)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900243/80-01 Program No. 51300 Company:

Pittsburgh-Des Moines Steel Company Central Division Des Moines, Iowa 50306 Inspection Conducted: August 25-29, 1980 Inspector:

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J. W. Sutton, Contractor Inspector y

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ComponentsSection I

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Vendor Inspector Branch Approved by:

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D. E. Whitesell, Chief

/ Dath ComponentsSection I Vendor Inspection Branch Summary Inspection on August 25-29, 1980 (99900243/80-01)

Areas Inspected:

Implementation of 10 CFR 50, Appendix B and applicable codes and standards including action on previous inspection findings; QA program review (Organization), nonconformance/ corrective action; review of vendor's activities; Authorized Nuclear Inspector (ANI) interface and audits. The inspectiot. involved thirty-two (32) inspector - hours on site by one NRC inspector.

Results:

In the six (6) areas inspected, no apparent deviations or unresolved items were identified in four (4) areas.

The following were identified in the remaining two (2) areas.

Deviation:

Audits - Annual corporate and division audits have not been con-ducted.

(See Notice of Deviation, Enclosure.)

Unresolved Items:

Nonconforming / Corrective Action - Clarification is re-quired as to the final review by QA of Engineering Corrective Action requests (Details Section Paragraph D.3.b. (2)).

Clarification is required as to how visual identification of nonconforming items is achieved (See Details Section, ParagraphD.3.b.(1))

8010240 O22

3 DETAILS SECTION A.

Persons Contacted Pittsbura;-Des Moines Steel Company - (PDM)

S. Biber, Central Division Manager

  • P. A. DeMars, Assistant to Division QA Manager A. M. DeVaul, Engineering Manager
  • R. W. Eastman, Corporate QA Coordinator
  • S.. M. Gates, Division QA Manager P. Husby, Drafting Technician
  • B. Mills, Regional Engineering Manager C. Pippett, QA Engineer, Clive Plant
  • J.~ E. Thompson, Division Production Manager L. H. Thomsen, Plant Manager, Clive Plant E. Wilborn, Welding Foreman, Clive Plant J. Wilson, Calibration Technician, Clive Plant actory Mutual Engineering James Wilson, Authorized Nuclear Inspector Supervisor (ANIS)
  • Denotes those persons who attended the exit interview.

B.

Action on Previous Inspection Findings 1.

(Closed) Deviation C.3.(1) (Report No. 77-01).

The inspector verified that additional staffing had been provided as stated in the October 24, 1977 reply from PDM.

2.

(Closed) Deviation C.3.2.(2) (Report No. 77-01).

The inspector g

verified that the ANI is being notified of manual changes.

PDM is logging all replies from the inspection agency and the current manual reflects all code changes.

3.

(Closed) Deviation E.3.a. (Report No. 77-01).

The inspector verified that the vendors of calibration services have submitted their calibration procedures to PDM.

4.

(Closed) Deviation F.3.a (Report No. 77-01).

The inspector verified that a Level III inspector'has reviewed and signed NDE personnel records.

5.

(Closed) Deviation G.3.a. (Report No. 77-01).

The inspector examined the. audits that have been performed. This item of failure to per-form annual audits is being resubmitted as a deviation as a result of the current inspection.

(See Notice of Deviation Enclosure.)

4 6.

(Closed) B.3.a. (Report No. 77-01). The inspector verified that a current Approved Vendors List has been generated and is being kept current.

The vendors are being audited as required by the QA manual.

C.

QA Program Review (Organization) 1.

Objectives The objectives of this area of the inspection were to ascertain whether PDM's Corporate QA manual Section 1 and Appendix D for the Clive Works is being correctly implemented.

Also, to ascertain whe-ther the QA organization is consistent with NRC regulations, contract and code requirements.

2.

Method of Accomplishment The preceding objectives were accomplished by:

Review of PDM's Corporate QA Manual, Revision 7, dated 12-12-79.

a.

b.

Review of Section 16 of the QA Manual, titled, "The QA Manual."

Review of Section 14 of the QA Manual, titled, " Indoctrination c.

and Training."

d.

Review of Appendix D, Revision 4, dated 1-15-80 to the Corporate QA Manual for the Clive works.

Review of appropria'e organization charts to verify that the e.

QA staff is independent from the pressures of cost and schedul-ing and has access to upper management.

f.

Review of the documents concerning the authority, duties, and responsibilities of the QA staff, to verify that they have the independence to identify quality problems, initiate appro-priate corrective action, and have the authority to stop work.

3.

Findings Within this area of the inspection no deviations or unresolved items were identified.

D.

Nonconformance/ Corrective Action 1.

Objectives The objectives of this inspection were to verify that:

5 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 12, " Deficiencies, Variations a.

and Nonconformances."

b.

Review of the Corrective Action /FCAR Log Book.

Review of selected nonconformances reports and Engineering c.

Corrective Action Requests (ECAR).

d.

Inspection of the designated hold and segregation areas.

Discussion with cognizant personnel.

e.

3.

Findings a.

Deviations None.

b.

Unresolved Items (1) Clarification is required concerning as how positive visual identification of nonconforming items is achieved.

At present nonconforming items are not visually identified by tags, markings, etc., to indicate that the item is nonconforming.

Nonconforming items are or can be stored with conforming materials while awaiting review of the ECAR.

The only identification would be inside a plastic envelope containing the FCL, which has been marked " Hold."

(2) Clarification is required pertaining to the review of ECAR. The present system does not provide for QA review of the final disposition of the ECAR as prepared by the Engineering Department prior to repair, use as is, or scrap. Under the review procedure QA oniv reviews the proposed corrective action to be taken.

QA has been placed on the distribution list after approval by the Engineering Department.

6 E.

Audits 1.

Objectives The objectives of this area of the inspection were to review the audit activities of the company to determine that the audit procedures and schedules are being properly and effectively implemented by the company.

2.

Method of Accomplishment The preceding objectives were accomplished by:

a.

Review of the QA Manual, Section 15, Titled " Audits" b.

Review of the Approved Vendors Lists, dated 8-18-80.

Review of a list of disapproved vendors.

c.

d.

Review of vendor audits and eurveys of vendors.

Review of vendor nonconformance reports.

e.

g.

Review of the records of lead auditors, dated 6-6-80.

i.

Review of audit schedules and audits performed on corporate and division levels.

3.

Findings a.

Deviations See Notice of Deviation Enclosure.

b.

Unresolved Items None.

F.

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

7 to be implemented for the achievement of interface activities that 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:

Review of the QA Manual, Section 1, Paragraph 1.4, to ascertain a.

whether the system provides for interface with the ANI and/or the Authorized Inspection Agency (AIA). This interface pro-vide for review of the Design Specification (DS), and the inspection services required by Code on all Code items covered by the customer's order and the DS.

b.

Review of nonconforming reports to verify that changes in the customer's DS are reviewed with the ANI.

Review of Shop Travelers to verify that they inform the ANI of the status of the inspections and tests of the items when removed from the manufacturing process, Review of QA Manual to verify thac reasures 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 reviess are documented.

d.

Review of QA Manual to verify that a system has been provided to maintain the identification of materials.

That the identi-fication is transferred then it becomes necessary to divide the material. Also to verify that the ANI is provided the oppor-tunity to verify that the identification of material it properly maintained and documented.

e.

Review of QA 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 ascertain whether they ANI may request the requalification of any pro-cedure or welder to ensure proper qualification and/or any welder performance qualification tests.

f.

Review of the QA Manual to verify that the program provides for the application of the Code stamp only with the authorization of the ANI after acceptable pressure testing, certification of the Manufacturer's Data Report, and stamping only in the presence of the ANI.

i I

8 4

g.

.The' Daily Log _ Book maintained by the ANI was reviewed, to verify that PDM is making its.QA/QC documents _available to the ANI for his review, to provide assurance that the Code requirements are

-complied with and that the product quality has been achieved.

3.

Findinas 13te ANI activities as documented in his log book, and by documents i

reviewed, supports a finding that the vendor is properly implementing its interface responsibilities with the ANI in a manner consistent with the NRC: rules, Code requirements, and its QA program commitments.

The ANI is an itinerant inspector on call by the vendor.

Review of Vendor Activities 1.

Objectives The objectives of this area of the inspection were:

?

l a.

To review the nuclear activity and work load to assess their impact of future NRC inspections.

i.

l b.

Evaluate the vendor's fabrication / manufacturing equipment and capabilities.

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2.

Method of Accomplishment The foregoing objectives were accomplished by observing the manu-facturing/ fabrication in progress, and. discussions with the cogni-zant vendor personnel.

j I

3.

Findings The vendor has the capability to design manufacture and test Class p

i, 2, & 3 and Mc vessels, Class 2 and 3 storage tanks and Class

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CS Core Support Structures. The vendor has the capability for cutting, I

forming and welding all metals, metal plates up to 3 inches thick.

j The vendor has the capability for all NDE, (MT), (PT), (RT), (UT),

-and (VT) activities.

The vendor can heat treat components up to 12X16 feet.

Shipping of completed products by rail and truck is 1

possible.

The' vendor: holds. valid ASME Certificates of Authorization for "N" and "NPT" stamps. The current active combined nuclear contracts for both the Des'Moines/Clive' Plants accounts for 25% of their total effort.

4 4

l

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9 The vendor currently has six (6) nuclear contracts in house.

G.

Exit Interview The inspector met with management representatives (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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