ML20031C982
| ML20031C982 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1981 |
| From: | Barnes I, Oller R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031C932 | List: |
| References | |
| REF-QA-99900715 NUDOCS 8110090179 | |
| Download: ML20031C982 (14) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report Nc. 99900715/80-01 Program No. 51400 C mpany:
G. H. Bettis Company 7031 Grand Blvd.
P. O. Box 14689 Houston, Texas 77021 Inspection Conducted:
December 15-19, 1980 Inspector:
2'8'8/
+
R. E. Oller, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch Approveo by: [ b W 2 - r -F1 I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch Suminary l
l Inspection on Decerrber 15-19, 1980 (99900715/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, 10 CFR Part 21 and other applicable NRC requirements including:
initial management meeting, QA program review, review of vendor activities, equipment calibration, internal I
aedits, manufacturing process control, and followup on Bettis Part 21 Report I
dated November 17, 1980.
The inspection involved 29 inspector-hours cn site.
Results:
In the seven (7) areas inspected, no deviations were found in six (6)
The following were found in the remaining area.
areas.
Deviations From Commitments:
Contrary to Criterion XVIII of Appendix B to 10 CFR 50, with regard to audit findings, followup action including reaudit of deficiant areas was not performed for two deficiencies found during the May 28, 1980 internal audit, nor was there written measures in the QA Manual to assure that followup action, by reaudit of deficiencies, would be performed.
(See Notice of Deviation)
Eb o
m 1
2 Unresolved Items None.
Other Findings The G. H. Bettis 10 CFR Part 21 Report, dated 11-17-80, met the requirements of 10 CFR Part 21; no items of noncompliance were identified.
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DETAILS SECTION A.
Persons Contacted
"*W. Bitterman, President E. Braun, Production Control Clerk W. Cornelius, Service Manager - Order Processing
" R. Hebner, Controller
"*K. Kimzey, Vice President - Manufacturing
" R. Krauss, Vice President - Engineering
"*A. Locascio, QA Manager
- R. McMakin, Product Engineering Manager
" N. Quam, Vice President - Sales & Marketing R. Reed, Jr., Nuclear Applications Engineer D. Shutt, Class A Inspector - Gage Room D. Tussey, QA Secretary
" Attended the Initial Management Meeting.
- Attended the Exit Meeting.
B.
Preinspection Meeting A preinspection meeting was held on December 15, 1980, with the QA Manager.
The NRC inspector discussed the areas to be inspected and the purpose and objectives of the inspection.
In addition, a time was set for a post inspec-tion exit interview.
C.
Initial Management Meeting 1.
Objectives The objectives of the Initial Management Meeting were to meet with Plant Management to establish communications, discuss the purpose and intent of the Vendor Inspection Branch (VIB) direct inspection program and to learn the basic functions of the plant.
2.
Methnd of Acccmolishment The preceding objectives were accomplished by the inspector's pre-sentation and the resulting discussions covering the following:
a.
N'IC policies and organization.
b.
VIB program objectives and how these objectives are to be accompiished.
c.
VIB organization.
a, 4
d.
Inspection areas to be covered.
e.
Basic inspection techniques of the VIB.
f.
Enforcementsprocedures applicable to vendors, including Section 206 of the Energy Reorganization Act of 1974 and Part 21 of 10 CFR.
g.
Thu White Book.
h.
Quer+'ons.
3.
Results No unusual questions or discussions developed er occurred during the initial management meeting.
This G. H. Bettis plant manufactures mechanical actuators for use with valves, dampers and other devices.
D.
QA Program Review The objectives of this inspection were to verify that the QA program has been documented in writing and has been implemented to control quality related activities.
Also, to ascertain whether program provides for the following:
Management's policy statements concerning QA.
a.
b.
The QA organization is structured to achieve organizational independence and freedom to:
(a)
Identify quality problems (b)
Initiate appropriate resolutions (c) Verify corrective actions.
The QA staff with the authority, and access to a level of c.
management that ensures effective implementation of the QA program elements, and to enforce positive and timely corrective action, d.
The duties, responsibilities and the authority of the QA staff are clearly delineated in writing.
Detailed written procedures, properly reviewed and approved, e.
are available to control quality related activities.
f.
A training and indoctrination program to provide and maintain the proficiency of; t
l.
5 (1) Personnel performing quality activities.
(2) Personnel verifying that quality activities are properly performed, g.
, Adequate control of procurement activities is performed.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the G. H. Bettis QA Manual No. QAM 1276-100, dated 4-26-79.
b.
Review of nine (9) approved quality control procedures specific-ally used to train personnel and implement the QC Department activities, and review of individual operating procedures for other departments such as engineering, sales, purchasing, pro-duction control, receiving and warehouse, industrial engineering, and manufacturing engineering.
c.
Review of G. H. Bettis Qualified Welder List and three welding Qualification Procedures specific to the welding processes used at Bettis.
d.
Review of Project Procedures Manual specific to the actuators for the Limerick project.
e.
Review of records of two (2) Action Requests and, three (3)
Material and Vendor Reject Tickets.
f.
Observation in the shop of holding shelves for segregation of rejected-reworkable parts.
g.
Review of records of the use of Traveling Requisitions and Purchase Orders used in procurement of materials and parts for use in the manufacture of actuators.
h.
Discussions with cognizant personnel.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
NI 6
E.
Review of Vendor's Activities 1.
Objective The objective of this area of the inspection was to assess the vendor's activities and their impact on future NRC inspections.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Discussions with cognizant personnel.
b.
Observation of actuator manufacturing facilities at the Houston plant.
Review of a list of nuclear actuator sales orders including these c.
in procest and those on hold.
d.
Review of G. H. Bettis sales catalog illustrations for the various types of actuators.
e.
Discussions concerning t.b.9 IEEE qualification of the Bettis actuators for safety related and LOCA service.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Other Findings (1) Bettis currently has two sales orders for nuclear service actuators and several sales orders on hold.
I (2) Bettis has successfully qualified actuator types "CB",
" Heavy Duty," and "T Series" to IEEE Standard No. 382, Draft 3, Revision 0, 1977.
I.
Equipment Calibration 1,
Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QA Manual i
and applicable NRC requirements:
A written system has been established to assure that equipment a.
calibration is performed and controlled in accordance with 4
i applicable requirements.
b.
A written procedure has been developed and approved which contains provisions to assure that tools, gages, instruments and other inspection, measuring and testing equipment and k
7 devices used in activities affecting quality, are of the proper range, type and accuracy, and are calibratod and properly adjusted at specified periods or use intervals.
c.
The devices are identified in the documented system and/cr procedure and are calibrated in accordance with the system and procedure.
d.
The calibration is performed against certified measurement standards which have known relationship to National Standards, where such standards exist.
The control measures include provisions for test equipment e.
l identification and calibration status by marking, or on records traceable to the equipment.
l f.
The Manufacturer provides corrective action for materials and items checked using measurement or testing equipment later found to be out of calibration.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of the QA Manual Section 12.0 " Control of Measuring and a.
Test Equipment."
b.
Review of approved " Calibration Procedures," and " Gage Room Attendent Procedures."
Observation of the calibration status of the following c.
measuring and testing devices esed in final acceptance inspection.
(1) Outside Micrometer Sets (2) Vernier Calipers (3) Depth Micrometer Sets l
(4) Optical Comparater (5) Height Gages (6) Surface Plates (7)
Profilometer (8)
Rockwell Hardness Tester
I 8
(9) Ring, Plug, and Thread Gages (10) Deadweight Tester (11) Hydrostatic Gages and Pneumatic Pressure Gages d.
Review of Bettis calibration record cards and subcontractor's certificates of calibration for the above devices.
e.
Discussions with cognizant personnel.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Followup Item Prior to the inspection of this area, the QA Manager indicated to the NRC inspector that the QA Manual did not properly identify certain calibration frequencies and equipment, and it was in a revised draft status to correct this condition.
The revised QA Manual will be implemented by March 1, 1981.
The above condition was verified during the inspection.
The corrective action for the above matter will be reviewed during a subsequent NRC inspec-tion.
G.
Internal Audits 1.
Objectives The objectives of this area of the inspection were to verify that the following items wer6 controlled in accordance with the QA Manual and applicable NRC requirements:
a.
A written system has been establisned to assure that internal audits are performed and controlled in accordance with applicable requirements to verify compliance with all aspects of the QA program.
b.
Planned and periodic internal audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibilities in the areas being audited.
c.
Audit results are documented and reviewed by management having responsibility in the area audited.
d.
Followup action, including reaudit of deficient areas, is taken where indicated.
.A&
9 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the QA Manual section 18.0 " Audits."
b.
Review of checklist, memorandum and corrective action records of internal audit of QA Department and of internal audits of the entire manufacturing program at the Houston plant, performed in May, 1979, and again in May 1980.
c.
Discussions with cognizant personnel.
3.
Findinos a.
Deviation From Commitments See Notice of Deviation.
b.
Unresolved Items None.
t H.
Manufacturina Process Control 1.
Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QA Manual and applicable NRC requirements.
a.
A written system has been established to assure that manu-facturing processes are controlled in accordance with appli-cable requirements.
b.
Measures have been established and implemented to control the manufacturing processes by use of process sheets, travelers, checklists or procedures.
c.
The process sheets, travelers, checklists or shop procedures used included:
the document numbers and revisions to which the processes, inspections or tests conformed; the results of completion of the specific operations; the signature, initials or stamp of the manufacturer's responsible representative and date were shown for operations completed.
1
\\
10 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following QA Manual Sections:
(1) No. 8.0, Identification and Control of Material, Parts and Components.
(2) No. 10.0, Inspection.
(3) No. 14.0, Inspection, Tests, and Operating Status, b.
Observations in the shop of six different actuator parts being manufactured and review of the following accompanying process control documents:
(1) Production Order and Process Sheet (2) Audit Inspection Sheet (3) Part Drawing c.
Observation in the final assembly area of actuators being assembled and review of the following accompanying assembly control documents :
(1) Sales Order (2) Bill of Material (3) Assembly Order (4) Assembly Drawing d.
Observation of actuators in the final test and inspection area and review of accompanying documents including those identified for the prior item.
e.
Observation of applicable Engineering Standards in the final test and inspection area.
f.
Discussions with cognizant personnel.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
11 I.
Followup On Bettis Part 21 Report Dated November 17, 1980, Malfunction of G. H. Bettis Actuator Model N-521C-SR Spring Return Unit 1.
Introduction On November 13 and 17, 1980, the NRC IE office was notified by G. H.
Bettis Company (Bettis), pursuant to 10 CFR Part 21, of a deficiency in the Model N522C-SR Actuator which might cause a failure of the actuator to stroke when air pressure is applied, if the actuator is adjusted beyond the 0-90 degree rotation.
Bettis indicated the spring cartridge part which is causing the problem can be changed to one with a longer spring guide sleeve, which will eliminate any possible occurence of the prob 1r.,,.
Bettis had prepared a list of customers who have ordered the !)321C-SR actuator, and Bettis will notify them of the possible occt,"rence of the problem.
2.
Objectives The objectives of this follow-up inspection were to ascertain that the reporting organization had implemented the requirements of 10 CFR Part 21 and had:
Met the requirements for reporting the deficiency.
a.
b.
Performed a safety hazard evaluation of the condition, and made an assessment of generic implications.
Assigned responsibility and implemented a plan of corrective c.
action.
d.
Reviewed preventive action measures.
3.
Method of Accomolishment The preceding objectives were accomplished by:
Discussions with cognizant personnel.
a.
b.
Review of the Bettis Part 21 Report dated November 17, 1980, to verify the following:
(1) The reporting requirements of 10 CFR Part 21 were met.
(2) The deficiency was properly evaluated and an assessment of generic implications was made.
(3) Adequate corrective action was implemented in a timely manner.
12 c.
Review of the Bettis internal memorandum dated November 13, 1980, covering the engineering evaluation of the potential actuator problem and assigning the reporting and followup of the problem to the QA Manager.
d.
Observation of the actuator spring sleeve associated with the problem.
e.
Review of drawings of the Model N521C-SR actuator in which the potential problem was identified, and the five different upring configurations which were affected.
f.
Review of the Bettis Engineering Change Notice No. 80-31941 providing for the change in the spring sleeves for the affected sctuator models, g.
Discussions with the QA secretary concerning the method by which it was determined which of the Bettis customers had received the affected actuators.
h.
Review of the Bettis actuator problem notification letters dated November 18, 1980, to the six affected customers, and discussions concerning responses to the letters.
i.
Review of the following customer purchase order specification to Bettis to determine what quality requirements were imposed on Bettis.
(1) Jamesbury Corporation, P.O. C-17138, dated 9-7-78.
(2) Henry Pratt Company, P.O. B-51014, dated 12-21-76.
(3) Fisher Controls Company, P.O. 7306697, dated 9-13-77.
(4) Duriron Corporation (Bettis Sales Order 74-073-00 dated 2-25-74).
(5) Posi-Seal International Inc., P.O. F-8013, dated 4-2-80.
4.
Findings Within this area of the inspection, no deviations, unresolved a.
items, or items of noncompliance were identified.
b.
Other Findings - Discussions and Comments (1) Discussions and review of the above documents established that the Bettis Part 21 Report, dated November 17, 1980, met the requirements of 10 CFR Part 21.
i b.
13 (2) The potential actuator problem was properly evaluated and reported in a timely manner.
(3) The generic considerations included a search of all sales orders back through 1974, when the first Model N521C-SR Bettis actuators were known to have been used in nuclear generating stations. The review verified that the affected actuators had been shipped to six customers.
These customers were notified by letters dated November 18, 1980.
Three customers have responded by telephone or letter asking for more informa-
- tion.
Bettis indicated they do not know the final use of the actuators.
This matter was discussed in the exit interview.
(4) The corrective action design modification was determined as applicable to five spring configurations involving the model N521C-SR actuator.
(5) Review of purchase order specifications from five of the six Bettis customers verified that only Fisher Controls specified that 10 CFR Pcrt 21 applied.
None of the speci-fications included QA requirements, (6) Subsequent to the inspectico the QA Manager was contacted by telephone on January 15. 1981, to ascertain:
a.
The status of customer response to the notification.
b.
Whether Bettis furnished fastallation and operating instructions to their customers, which addressed adjustment requirements for the actuator.
The QA Manager responded by letter on January 27, 1981, indicating that four customers (Hanry Pratt, Jamesbury, Posi-Seal and Xomox) had currently responded and that Operation and Maintenance Manuals were furnished to all customers.
On February 2,1981, the QA Manager was again contacted by telephone on customer response status and indicated a followup letter would be sent to Fisher Controls and Duriron, requestirg a response relative to actuator use.
J.
Exit Interview 1.
The inspector met with persons denoted in paragraph A at the conclusion of the inspection on December 19, 1980.
i
EF" -
i 14 2.
The following subjects were discussed:
a.
Areas inspected.
b.
The inspection findings identified in this report.
c.
The manner in which the manufacturer's representatives should respond in writing to deviations from commitments.
3.
The subject of the slow responses by Bettis' customers to the 10 CFR Part 21 potential problem was discussed.
Since Bettis did not know the specific site service for the affected actuators, the NRC inspector indicated there may be an IE Bulletin or Infor-mation Circular issued to license holders.
4.
Management's questions related to clarification of the abovt items.
o