ML20023D327
| ML20023D327 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20023D320 | List: |
| References | |
| REF-QA-99900056 NUDOCS 8305200376 | |
| Download: ML20023D327 (5) | |
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APPENDIX A Henry Pratt Company Docket No. 99900056/83-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on February 14-18, 1983, 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 Part 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 accord-ance 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."
Nonconformances with these requirements are as follows:
A.
Subsection NCA-4134.2 of Section III of the ASME Code, 1980 Edition, states, in part, "The Program shall provide for indoctrination and training of personnel performing activities affecting quality... It shall be the responsibility of the Certificate Holder to assure that all personnel performing quality functions... are qualified...."
Paragraph 5.5.7.1 of Section 5, Revision 1, of the Quality Assurance Manual (QAM) states, in part, " Personnel performing activities affecting quality... shall receive training and indoctrination...."
Paragraph 5.5.7.2 states, in part, " Department supervisors shall be responsible for the general training of their personnel. The QA manager shall be responsible for monitoring such training programs."
l Contrary to the above, a review of auditor qualifications and QA Training /
Indoctrination Records from 1979 through 1982 revealed the following:
1.
Employee No. 9663 had performed internal audits in August and September 1981, but was noted on the Record of Auditor Qualifications as being qualified during this time frame to perform only vendor audits.
2.
No documented evidence that employee No. 6898 who had calibrated measuring and test equipment (M&TE) used on nuclear valves was trained or indoctrinated.
3.
No documented evidence that the shop personnel associated with the
" elastomer seat" process had received any training in the activities relating to this process.
9305200376 830428 PDR GA999 EMVHENR 99900056 PDR
. B.
Subsection NCA-4134.4 of Section III of the ASME Code,1980 Edition, states, in part, "... procurement documents shall require supplier to provide a Quality Assurance Program consistent with the applicable requirements of this Section."
Paragraph 10.4.4.3 of Section 10, Revision 2, of the QAM states, in part,
" Purchase orders shall be... approved by QA Manager prior to issuance to vendor. Purchase Order Nos. for materials and services for nuclear orders shall be identified with a 'U' prefix."
Contrary to the above, a review of purchase orders to Wyle Laboratories to perform seismic vibration tests on nuclear valves and to three vendors (Chemical Products, Hughson Chemical, and Lavelle Rubber) supplying material used in the " elastomer seat" process for nuclear valves indicated that the purchase orders:
(a) contained no requirements for the vendor to have a QA program, (b) were not approved by the QA Manager, and (c) were not prefixed with a "U".
C.
Subsection NCA-4134.7 of Section III of the ASME Code, 1980 Edition, states, in part, "... measures shall include... provisions... for source evaluations...."
Paragraph 10.3.1 of Section 10, Revision 2, of the QAM states, in part, "QA Manager shall be responsible for approval of vendors for Nuclear Projects."
Paragraph 10.4.3 states, in part, "... materials, services... shall only be purchased from approved vendors."
Contrary to the above, a review of vendor audit reports from 1979 to the present and a review of the Approved Vendor List for the years 1981 and 1982 revealed that the following vendors were neither surveyed nor audited:
(a) Wyle Laboratories - welded angle bracing on a nuclear valve assembly and performed seismic testing on nuclear valves; and (b) Chemical Products, Hughson Chemical, and Lavelle Rubber - suppliers of material used in the
" elastomer seat" process for nuclear valves.
D.
Paragraph.E.5.7.2 of Section 8, Revision 2, of the QAM states, in part, "All revised documentation must be reviewed and approved using the same controls as the original documentation...."
Contrary to the above, letters dated November 15, 1982, from the Henry Pratt Company (HPC0) to Lavelle Rubber Company and August 9, 1982, from HPC0 to Albert Trostel Packings, Ltd., had not been reviewed and approved using the same controls as the Resiloseal C Rubber specification dated March 1, 1982. The contents of these letters formed the basis for accepting the revision of the rubber from the vendors that was not the same as values in the original specification.
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t E.
Paragraph 5.6 of Quality Assurance Procedure No. 31, " Control of Nuclear Class Valves, Spare Parts and-Replacement Parts, Inquiries and Others,"
Revision B, requires activities (e.g., procurement, inspection, testing, final documentation, etc.)' relating to the rework and repair of nuclear i
valves to be in accordance~with HPCO's QA program for nuclear valves which is described in the QAM.
Paragraph 12.5.3 of Section 12,' Revision 2, of the QAM requires that
- identifying numbers such as heat and/or serial numbers be traceable to material manufacturers' test reports arid that the heat and/or serial numbers be entered on test records.
Contrary to the above, a review of quality data packages (which included material certifications, test reports, etc.) relating to the repair of three 18" safety-related butterfly valves for Connonwealth Edison (Job I
Nos. D-28261, D-28262, and D-28254) indicated the absence on test records of heat, serial, or other identifying numbers to assure material traceability.
F.
Paragraph 9.5.1.1 of Section 9, Revision 1, of the QAM states, in part,
"... Nuclear Methods Sheets show the following information 'in their proper sequential order..
9.5.1.1.6 Description of welding, heat treating, and all special processes... with reference 't'o Pratt Procedure numbers and revision..
9.5.1.1.8 Description of required examinations and tests with reference to Pratt Procedure numbers and revisions...
9.5.1.1.10 Description of special cleaning with reference to Pratt Procedure numbers and revision."
Contrary to the above, Nuclear Methods Sheets did not reference a Pratt -
l procedure number and revision for the following operations associated with
[
two nuclear valves:
Job No. D-28261 -
1.
Hydrostatic test of the body at 300 psi for 10 minutes; 2.
Leak test at 150 psi for 5 minutes, both sides of disc; 3.
Operate valve three times open and close; and 4.
Clean and prepare valve for final inspection.
Job No. D-28262 -
1.
- Prepare body for rubberizing, and 2.
Rubber body with EPT material.
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G.
Paragraph 7.3.1 of Section 7, Revision 2, of the QAM states, in part, "The Project Manager is responsible for coordinating determination of order requirements...."
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. Commonwealth Edison purchase orders (P0s) 728271, 725088, and 729479 state, in part, "... QA Documentation Requirements: Certificate of Conformance that seat material EPT compound Resiloseal
'W' will perform at 250' max allowable service temperature and material will resist radiation exposure...."
Contrary to the above, a review of quality data packages relating to the three nuclear valves for Commonwealth Edison indicated there was no evidence that the bonding agent for the valve seat had been tested at the required temperature and radiation levels nor had tests been conducted to determine valve (seat) performance after being exposed to the allowable service temperature and radiation.
H.
Subsection NCA-4134.12 of Section III of the ASME Code, 1980 Edition, states, in part, " Calibration shall be against measurement standards which have known relationship to national standards... Control measures shall include provisions for identifying measuring and testing equipment...."
Paragraph 5.5.1 of Section 5, Revision 2, of the QAM states, in part,
" Tools, gages, instruments, and the measuring and testing devices...
shall be calibrated and properly adjusted at specified frequencies...."
Paragraph 5.5.1.2 states, in part, "... Gage serial numbers are marked on the instruments. Calibration labels... showing date calibrated, signature, and re-calibration due date, are affixed to instruments or instrument case when released for use."
Paragraph 6.3 of Procedure No. QAP-2, April 22,1971, states, in part, "A schedule for calibration frequency for gages and secondary standards is listed in Para. 7.0..
7.0 Calibration Frequency..
7.31 Shore Durometer Hardness Gages - 24 months." Paragraph 8.3.2 states, in part,
" Shore Durometer Hardness Gages..
8.32.3 Quality Assurance maintains certifications and records of calibrations.
Calibration sticker is applied if the gage is found acceptable."
Contrary to the above, three measuring and testing devices were observed in the inspection area for elastomer seats on nuclear valves with the following results:
1.
Brinell Hardness Tester (King Tester Corp.) had no serial number, and the calibration due date of August 1982 as noted on the sticker was not met.
2.
I.D. Micrometer (No. 823C) had no serial number.
3.
Shore Durometer (Type A - Model 306L/ Serial No. 8028) had not been calibrated on a 2-year frequency, and a calibration label was not attached to the instrument or its case.
In addition, the QA Manager told the NRC inspector that there was no calibration performed to secondary standards on this instrument.
. A review of calibration records from 1975 through 1982 also revealed that master gage block HPC0-GB-202 used to calibrate M&TE for nuclear valves did not have any certifications for the years 1976 through 1982.
I.
Subsection NCA-4134.18 of Section III of the ASME Code, 1980 Edition, states, in part, "A comprehensive system of planned and periodic audits shall be carried out-by the Certificate Holder's organization to assure compliance with all aspects of the Quality Assurance Program...."
Paragraph 5.5.4.1 of Section 5, Revision 2, of the QAM states, in part, "... Each responsible area shall be audited at least once per year."
Contrary to the above, a review of internal audit reports for 1979 through 1982 including 19 audit checklists used for internal audits revealed that the activities associated with the " elastomer seat" process were not audited from 1979 to the present time.
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