ML20010H703
| ML20010H703 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/1980 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Keinmuth G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML17272A975 | List: |
| References | |
| FOIA-81-223, REF-QA-99900711 NUDOCS 8109290160 | |
| Download: ML20010H703 (1) | |
Text
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UNITED STATES enreg*e..
NUCLEAR REGULATORY COMMISSION 1r-es -
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REGION IV
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~ ft 611 RYAN Pt.AZA DRIVE, SUITE 1000 E
' art.INGTON, TEX AS 76012 17 APR 1980-MEPJ0RANDUM FOR:
G. W. Reinmuth, AD RCI 'Hqs fROPj; Uldis Potapovs, Chief, VIB, RIV
SUBJECT:
INSPECTION OF LECKENBY C0.
- The enclosed report on our recent inspection of the Leckenby Co., shows a large number of deviations from applicable QA/ contract specification requirement in the areas of kelding procedure qualifications, production welding, performance of weld repairs, non-destructive testing and manufacturing process control.
The company does not have N-stamp authorization but-is a supplier of non-code nuclear components including reactor sacrificial shield wall components, pipe rupture restraints, high density spent fuel storage racks and rad-waste handling
. equipment..
Gu-inspection was aimed mainly at the spent fuel storage racks (7 active contracts) and was triggered'by RV investigation of fabrication deficiencies related to the WPPS sacrificial shield wall.
It is our understanding that RV is considerisig es-calated enforcement against WPPS based on their failure to exercise adequate vendor
- rveillance.
In reviewing the active contracts for spent fuel racks, we found inconsistencies in the safety classification of these items. Some were classified as Safety Class I, others as Safety Class II and some had no safety class designation.
In view of the large number of deviations involved and uncertainties concerning the safety classification of these items, this report is forwarded to you for infor-mation and possible action.
. e plan to follow up on the identified deviations in a routine manner and verify W
that appropriate corrective action is achieved.
For additional information con-cerning this subject please contact D. E. Whitesell or V. H. Ilunter.
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- otapovs, Vendor Inspection dranch
Enclosure:
Report 99900711/80-01 cc:
G. Spencer, RV D. E. Whitesell, RIV V. H. Hunter, RIV 1
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DOCUMENTHASppTBf i
THI REV1 r0R OpRIETAR)
= g V%g UNITED STATES INFOR.
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jef NUCLEAR REGULATORY COMMISSION
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IN 10
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Docket No. 99900711/80-01 lackenby Company Attn: Mr. P. D. Moore Quality Assurance Manager 2745 lith South West Seattle Washington 98124 Centlemen:
This refers to the QA Program inspection conducted by Mr. V. H. Hunter of this office on March 17-20, 1980, of your facility at Seattle, Washington, associated with the fabrication of nuclear fuel racks and to the discussions of our findings with Mr. B. E. Weeks and members of your staff at the conclusion of the inspec-tion.
This inspection was made to confirm that, in the areas inspected, your QA Program is being effectively impicmented.
The inspection effort is not designed to assure that unique quality requirements imposed by a customer are being 41emented; nor to assure that a specific product, component or service provided by you to your customers, is of acceptable quality.
As you know, the NRC-requires each of its licansees to assume full responsibility for the quality of specific products, components or services procured from others.
You should therefore not conclude that the NRC's inspection exempts you from inspections by an NRC licensee or his agents nor from taking effective cor-rective action in response to their findings.
Areas c=4ned and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an evnmination of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection it was found that the implementation of your QA Program failed to meet certain NRC requirements.
The specific findings and references to the pertinent requirements are identified in the enclosures to this letter.
Please provide us within thirty (30) days of your receipt of this report a written statement contnining, (1) a description of steps that have been or will be taken to correct these items, (2) a description of steps that have been or will be taken to prevent recurrence, and (3) the date your corrective actions and preventive measures were or will be completed.
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' Docket No. 99900711/80-01
-In accordance witt.Section'2.790 of the Commission's " Rules of Practice,"
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Part 2. Title 10, Code of Federal Regulations, a cc.py of this letter with enclosure and your reply, together with the enclosed inspection report will be placed in the Commission's Public Document Room.
If this report ccntains any information that you believe to be proprietary, it is necessary that you mka a written application within thirty-(30) days to this office to withhold such infort tion from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the informa-tion is proprietary, and should be prepared so that proprietary information identified ~in the application is contained in a separate part of the document.
If we' do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, V
2 N)
Uldis Potapovs, Chief l
Vendor Inspection Branch Enclocures:
[
1.
Notice of Deviation l
2.
Inspection Report No. 99900711/80-01 l
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Docket No. 99900711/80-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on March 17-20, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
A.
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 instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantita-tive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." In addition, customer contracts imposed American Welding Society (AWS) DI.1 and SNT-TC-1A.
Deviations from these requirements are as follows:
1.
AWS D1.1 requires the actual amps, volts, and travel speed be recorded for FCAW and ESW weld procedure qua'lifications.
Contrary to the above requirements, the amps, volts, and travel speed were not recorded for the qualification of WP-00-12-13-06 which was used in production welding on Contract No. 2808-90.
2.
AWS DI.1 requires the actual number of weld passes be recorded or specified on the weld procedure (WP) for FCAW and ShAW processes.
Contrary to the above requirements, the actual number of weld passes were not recorded on WP-00-20-01-02 which was used in production welding on Contract No. 2808-90.
3.
Contract specification 2808-90 requires weld procedures to be qualified to the thickest material tc be used which was four (4) inches for FCAW and SMA processes.
Contrary to the above requirement WP-00-20-01-02 had been qualified for a one (1) inch maximum thickness and later used to produce four (4) inch production welds on Contract No. 2808-90.
4.
ESW WP-00-12-13-06 was qualified to weld in a thickness range of 1.5 to 3.3 inches.
Contrary to the above requirement, WP-00-12-13-06 was used to produce four (4) inch production velds on Contract No. 2808-90.
5.
Both AWS DI.1 and contract specification 2608-90 requires post weld heat treatment of test plates for the ESW welding process procedure qualifications.
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Contrary to the above requirement, test plates were not post weld heat treated for the qualification of WP-00-12-13-06 which was used in production welding for Contract No. 2808-90.
6.
.ESW WP-00-12-13-06 was qualified with a two (2) electrode technique in accordance with AWS DI.1.
Contrary to the above, WP-00-12-13-06 was used in production welding of Contract No. 2808-90, with a single electrode technique.
7'.
SNT-TC-1A requires three types of test examinations for all levels of nondestructive test (NDT) personnel certifications.
Contrary to the above requirements, one (1) NDT technician was certi-fied as a level II MT inspector with no documented evidence of exam-inations.
8.-
Customer Contract No. 280F-90-EC requires all NDT personnel to be certified in accordance wit SNT-TC-1A.
Contrary to the above requirement, one (1) individual performed acceptance ultrasonic test (UT) on steel plates identified as.b56 and F56 without being qualified for UT.
9.
Contract No. 2808-90-EC requires that UT be performed after post veld heat treat.
Contrary to the above requirement, the UT report for job numbers 5869 and 0124 were dated two (2) days prior to post weld heat treating.
10.
SNT-TC-1A does not permit a level I NDT inspector to conduct indepen-dent tests, interpret ny test results, or write a report of test results.
Contrary to the above req 'rements, a level I NDT inspector did conduct, interpret, and issue a report for a liquid penetrant (LP)
. test of module base 3A, item No. B-10 (spent fuel rack) on 5-28-78.
11.
SNT-TC-1A requires all NDT personnel to be certified by examination.
Contrary to the above requirement, one (1) individual was certified on 6-12-79 and performed level II LP inspections without having been examined.
12.
SNT-TC-1A requires all NDT personnel to be certified by examination.
Contrary to the above requirement, two (2) persons were certified on 6-12-79 for Level II leak testing and performed said leak tests
-without examination.
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- 13. AWS D1.1 requires either acid etching, magnetic particle test (MT),
or LP to define the extent of cracks.
In addition, it requires that sound metal be removed at both ends of the crack prior to weld repairs.
Contrary to the above requirements, neither acid etching, MT, or LP was used to define the extent of cracks, nor was sound metal removed prior to making weld repairs for rejection tag numbers 5256, 5325, 5412, 6055, 6056, 6058, 6059, 6069, 5443, 5444, 5445, 5446, and 5447 for Contract No.- 2808-215.
- 14. Customer contracts require the vendor to submit its quality assurance (QA) manual for review and approval.
Contrary to the above requirement, the vendor's QA manual was com-pletely revised on 3-10-80, but was not submitted to the customer for review and approval.
- 15. Quality Control Procedure No. 7.3 requires rejected material to'be identified by a red rejection tag and placed in a segregated area.
Contrary to. the above requirements, approximately fif ty (50) fixed spanners for Job No. 6780 were found to have been rejected and placed in segregatica but was not identified with red rejection tags.
- 16. Department Operating Procedure No. 615.0 states that manufacturing will not proceed past an inspection operation until said operation is " bought off."
Contrary to the above requirement, it was observed that operation numbers 885 and 890 of manufacturing 3ork order (shop traveler) No.
6738-5 were bypassed.
The two (2) operations were for ;imensional and LP inspections respectively.
- 17. Contract No. 231073 requires all welding to be performed in accordance with qualified and approved welding procedures.
Contrary to the above requirement, it was observed that welding was being performed on a spacer block type A assembly identified as job number 6738-21 without a qualified or approved welding procedure.
In addition, said welding was being performed with an uncalibrated unit.
- 18. All of the vendor's welding procedures using weld wire, specify a required wire travel range, e.g. 41 to 49 inches per minute for weld procedure No. 701A-6738.
Contrary to the above requirement, the vendor does not verify weld wire travel speeds on a routine basis.
4 B.
Criterion XVII of Appendix B to 10 CFR 50 states:
" Sufficient records shall be maintained to furnish evidence of ' activities affecting quality. The records shall inciude at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analysis.
The records shall'also include closely related data such as qualifications of personnel, procedures, and equipment.- Inspection and test records shall, as a minimum, identify the _ inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable.
Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility."
Contrary to the above requirements, the actual inspector for approximately one hucJred two (102) NDT reports for contract no. 2808-90-EC could not be identified. Examples as follows:
1.
LP inspection report no. 5308 showed a photocopied signature of an LP inspector while the inspection report data had been entered at a later date in a different hand writing.
.c 2.
The NDT inspector's signature had been photocopied for NDT report no. PWS 1-1 while the inspection data was entered later by an uniden-tified person.
C.
Criterion II of Appendix B to 10 CFR 50, states in part; "The applicant shall establish --- a quality assurance program which complies with the requirements of this appendix.
This program shall be documented by written policies, procedures or instructions and shall be carried out ---
in accordance with those policies, procedures, or instructions."
Contrary to the above, the Leckenby Quality Assurance Manual, Revision 5, dated March 7,1980, had not been documented by written policies, procedures and instructions in a manner consistent with the requirements of Appendix B to 10 CFR 50.
As an example, the QA manual does not prescribe a system to control design to assure that the design basis and related quality activ-ities are correctly translated into fabrication drawings, bills of materials and procurement documents and that deviations from such standards are properly controlled.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900711/80-01 Program No. 51400 Company:
Leckenby Company 2745-lith South West Seattle, Washington 98124 Inspection' Conducted: March 17-20, 1980 Inspectors:
fyy[J OY' V. H. Hunter, Contractor Inspector Date Components Section-I Vendor Inspection Branch pY 00 D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch 6
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/4/80 Approved by:
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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 Criteria and appli-cable codes and standards; including initial management meeting, QA manual i
reviev, 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 D1.1 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
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2 thickness welded as required by AWS D1.1, contract no. 2808-90-EC, and Appendix B to 10 CFRuSO (Notice of Deviation Items A.3 and A.4).
Post weld heat treat-ment not-performed on weld test plates in accordance with AWS DI.1 and Appendix B to 10 CFR 50.
(Notice of Deviation, Item A.5) Production welding performed with one (1) wire method which was not qualified in accordance with AWS D1.1 and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.6).
Production Welding - Welding without an approved procedure (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 plate 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 weld heat treating as required by AWS D1.1 and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.9) one (1) level I LP inspector conducted and issued an a ceptance 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 certif'.ed 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, Item A.12) one (1) NDT supervisor signed a blank NDT test report and p'ioto-i
.apied approximately one hundred and two times.
Said test reports were then completed and issued by unknown persons for two (2) years which is contrary 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 Appendix B to 10 CFR 50 (Notice of Deviation, Item A.13).
Quality Assurance Program - QA manual not submitted for approval in accordance with customer 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 Appendir D to 10 CFR 50 (Notice of Deviation, Item C).
Manufacturing - Inspection hold points by passed which is contrrry to DOP 614.0 and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.16).
Jeld wire travel speeds not documented as required by Appendix B to 10 CFR 50 (Notice of Devia-tion, Item A.18).
Rejected material rot identified as required by QCP 7.3. and Appendix B to 10 CFR 50 (Notice of Deviation, Item A.15).
I
3 DETAILS SECTION A.
Principal Persons Contacted
- B. E. Weeks, Chairmaa
- R. D. Pittsenbarger, Chief Engineer
'*A. E. Kur.zler, 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.
Objectives The objectives of this meeting were to accomplish the following:
To meet the Leckenby Company management and those individuals l
.a.
l responsible for the administration of the QA program. Also to l
establish channels of communications.
l l
b.
To determine the extent of the company's involvement in the commercial nuclear business, i
l c.
To explain NRC direct inspection program including the Vendor Inspection organization and inspection methods and documentation.
2.
Method of Accomplishment The foregoing objectives were accomplished by a meeting on Monday, j
March 17, 1980.
The following is a summary of the meeting:
1 a.
Attendees were:
l 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 s
4 V. Hunter, 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 vera 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.
The inspectors were conducted on an orientation tour of the e.
Leckenby Offices and Shops.
3.
Results The Leckenby Quality Assurance Manager was identified 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 processed in-house.
The components includes Reactor sacrificial shield walls, high density poison spent fuel storage rac'rs, " 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 current 1-holds an ASME Certificate of Authorization number 14,759,;9 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 fer Certificate of Authori-j zation to use the ASME A and PP stamps, on March 8, 1980.
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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 Accomplishment 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 requirements 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 activitics 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.
Review of the organization charts to ascertain whether the c.
QA organization was structured within the Company in a manner which provides the following:
(1) Acccss 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 implemented, and have been vested with authority to stop work until the problem is appropriately dispositioned.
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O 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 t manner consistent with tN: NRC rules and regulations, and contract requirements and the company's commitments.
Discussions with the company's cognizant personnel.
c.
3.
Findings 1
The contract documents specified that the Leckenby Company were
-a.
I 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 implementation 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 objective 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 a
The foregoing objectives were accomplished by:
Review of Section 3, Design Control, of the QAM.
a.
b.
Review of the latest revisions of the Customers Design l
Drawings and Technical Specifications for the Sacrificial Shield Wall manufactured by Leckenby under Contract Nos.
q 2808-215, and Leckenby, Fabrication and Assembly drawings
{
for Job Order no. 5758, Revision 8, dated 7/25/75, to verify 1
that the customer quality requirements had been correctly translated to the in-house manufacturing documents.
1
r I
Review of the Advance Bill of Material for Job' No. 5758 to c.
verify that the size, type and grade of materials were in gj-compliance with 3he 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 determinad 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 procedures 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 m.terials, Q
4
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procedures, instructions, or check list to ensure compliance with all of the customers specified quality requirements.
. The procedure as approved and its implementation will be verified during the next inspection.
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E.
Control of Special Processes 1.
~0bjectives 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.
l 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 on M0 No.
6738-21.
j.
Reviewed approximately twenty (20) NDT personnel qualification records.
k.
Interviews with all available personnel.
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. Tospection Findings
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a..
Deviations
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C See Notice of Deviation.
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b.-
Unresolved Items 2X-
" ' ~iE' None were identified
~ ' ^ F.
Exit' Interview
]The inspectors met with management representatives (denoted in paragraph
'eA.) at the conclusion-of the inspection on March 20, 1980.
Management
- representatives were advised that time did not permit a full review of the'ir QA program implementation.
However, the areas covered did disclose twesty (?.0) significant deviations from commitments which indicates thatiLeckenby 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 representatises commented that corrective actions were being made in several areas at the time of this inspection, and further, that Lechenby 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 insp2ctor 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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