ML20031D143
| ML20031D143 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/1981 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Davis E PRECISION SURVEILLANCE CORP. (FORMERLY INRYCO, INC.) |
| Shared Package | |
| ML20031D140 | List: |
| References | |
| REF-QA-99900731 NUDOCS 8110090402 | |
| Download: ML20031D143 (5) | |
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M UNITED STATES NUCLEAR REGULATOR'. COMMISSION
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,E REGION IV
- 5-k 611 RYAN PLAZA DRIVE. SUtTE 1000 ARLINGTON. TEXAS 76011 g
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-Docket No. 99900731/80-01 INRYCO, Incorporated Concrete Systems Group Attn: Mr. E. Davis
. Assistant to the Vice President t
Box 1009, 1550 N.' 25th Avenue Melrose Park, Illinois 60161
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Gentlemen:
1 After review c ? your letter of March 23, 1981, in response to our letter of l
February 12,-1981, we find that your reply is unsatisfactory, both in an i
attitudinal sense and in regard to apparent adequacy of actionr taken with respect to specific identified nonconformances.
As a result of our review, we
~ find that additional information is needed on the Ollowing items in the Notice of Nonconformance:
i Item B.1 The NC/CA Report Fonn is used to identify and document conditions adverse to quality. However, the cause of a condition is provided only for "significant conditions." Therefore, please provide the method (s) used for differentiating between "significant" and
" nonsignificant" conditions, and the means by which this is docu-mented.
In addition, is the investigation into the cause of nonconforming condi tions, as described in Title XVI, Section 3 of the QA Manual, documented?
item B.2 The fact that certain NCRs predate the present QA/QC administration, is not a justification for their remaining open, when actions had been taken which should have closed them out.
While you did address your actions taken to correct the specific NCRs, you did not state the actions taken, or to be taken, to prevent recur-rence of this problem on any future NCRs.
Please provide this infor-mation along with the date(s) for completing these actions.
Item C The NRC inspector documented the INRYC0 QC Inspector's entire response pertaining to NCR 791-51S.
Information pertaining to the process of consolidating all defective coils of wire on one NCR was not provided to the NRC inspector.
The NRC Inspection Report (S0-01) did document the fact that all defective wire coils were identified with Hold Tags.
8110090402 810709 PDR GA999 EMVINfW -
99900731 PDR
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- INRYCO,; Incorporated 2
-~Your attention'is -called to Title XV Section 1 of the QA Manual, which s'tates-in part, "Any item --- not conforming --- will be documented as.a nonconformance. A nonconformance report will be written....
This reporting will be completed on a timely basis... -.
In no case will_ the reporting action exceed 30 days from discovery to actual distribution."
While your stated reasons for the consolidated approach are under-standable, they.do not comply with the above QA Manual commitment, in that NCR 791-51S was originated on July 24, 1980, voided out on September 29, 1980, and new NCR-56S was issued on December 10, 1980.
By initiating NCR-56S, it appears that your corrective action is
. complete.
However, please provide us with the measures that have been or will be taken to' prevent recurrence of not complying _with the 30 day requirement and the dates these actions will be completed.
Item D.
We request clarification of your response to this item.
-You state in your response that Procedure Q675-G has been voided in favor _ of Engineering Computer Program "JKCALNRG" and the QA and QC sections were not aware that Q675-G had been removed from the computer.
It would appear from your response, that Procedure-QA9.1.G was actually used for the calibration of the identified rams.
Please address the following questions.
1.
How was procedure QA9.1.G denoted to be applicable for use to the personnel performing calibration of the identified rams?
2.
Are the pressure points, stipulated in QA9.1.G, at which the values for calibration of stressing rams are to be read, con-sistent with the pressure points actually used on the identified rams?
Item F.
With the exception of Auto Truck Steel Body, you have failed to respond to the nonconfonnance as stated in the Notice of Nonconformance,
... the methods used to evaluate and qualify certain approved vendors have not been documented."
Please provide your corrective actions, actions to prevent recurrence, and the dates by which these actions will be completed.
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ii 21NRYCO,. Incorporated' 3
You state in your response to Item F that the NRC inspector overlooked, or failed to request certain doct.utents.
The NRC inspector requested files pertaining to INRYCO's evaluation, qualification, and audits of certain vendors.
The NRC inspection report was based'upon the files that were presented in response to that request.
Your statements in regard to, improper classification of vendors on the AVL being the result of. typographical errors raise additional concerns. That such a situation could have occurred indicates a failure on the part of QA to' perform even a basic review of a central procurement control element.
You are therefore requested to provide us with a statement addressing the-documented actionc that have been or will be taken to assure that vendor use in the future will be correctly designated on the AVL.
Item G.
Your response states that procedure No. HT101 does not specify tempering temperature. While it is agreed that the document is titled "Reconnended Heat Treatment Temperature" and the heading of the tempering temperature column is labeled " Approximate," please explain the note under Table I which states in part, " Tolerance on tempering. temperature - The tempering temperature will be allowed to vary by plus 100 F due to the variations in the chemical composition of the steel being treated."
There is no allowance for a reduction in tempering temperature.
Thetemperingtemperaturecolumnshowsarangeof950F-3'000Ffog 4140 steel.
The tolerance note would allow a range of 950 F - 1100 F, g
but not a reduction to 920 F or lower as shown on the identified heat treat charts.
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Commentary:
),
The following is provided in response to your questions and statements in the
" Final Comnentary" portion of your response, although it is not pertinent to the inspection.
Section 1.
I The NRC inspection, conducted at INRYCO, was perfonned in accordance l
with 10 CFR Part 50, Appendix B criteria.
Initial notification to j
INRYC0 was made by telephone on October 17, 1980, with a confirmation letter dated October 20, 1980. The letter to Mr. M. Johnson, Nuclear Projects Manager, confinned the discussion pertaining to the agreed upon inspection conducted on November 17-21, 1980.
Upon arrival at INRYC0 on November 17, 1980, the NRC inspectors were escorted to the office of Mr. E. Davis where introductions were made, the scope of the inspection was discusscd, and questions relative to the NRC inspection and scope were answered.
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INRYCO,. Incorporated:
4 Both 10 CFR Part 50 Appendix B 'and ANSI N45.2.12 a.llow 'the use of either. checklists or' written procedures.
The NRC inspectors used w.itten ' procedures (inspection modules). which clearly define inspec-tion objectives, inspection requirements, and provide inspection-
- guidance.-. The inspection modules have been developed for the various
- elements of %ppendix B criteria to 10 CFR Part.50.
Section 2.
f The Vendor Inspection Branch conducts reactive inspections pertaining to identified nonconformances..The inspection conducted at INRYC0 falls in that category.
Section 3.
INRYC0 was included in the NRC inspection program as a result of NRC receipt of Construction Deficiency Reports.
It is the responsibility of the Office of Inspection and Enforcement, Vendor Insnection Branch, to inspect those companies idcntified as providing deficient parts /
materials to a user licensed by NRC.
Section 4.
Region IV or Region II of the NRC's Office of Inspection and Enforcement did not make any external distribution of the inspection findings or inspection report prior to the 25 day proprietary information response period.
It should be noted, however, that we would not consider this an improper act if,'in fact, it had occurred. Provided no proprietary information is divulged, we have no reservations concerning release of NRC inspection findings to NRC licensees.
As you are aware, both the i
inspection report and related correspondence are placed in the Public Document Room. There is no such thing as auditor - auditec confidenti-al i ty.
We regret both the tone of the INRYC0 response, and the apparent ongoing misunder-standing of the reasons for performing an inspection at your facility.
It was our view after the meeting with you in this office on December 11, 1980, that our discussions had dispelled any such misunderstandings, Your response to our i
inspection report indicates our view was incorrect and also raises additional concerns on our part, with respect to the adaquacy of involvement in the INRYC0 quality assurance program and recognition of its importance by the responsible officers of your company.
Should you wish to visit this office for any clarifi-cation of our position, we are available for such discussion.
We shall be contacting you shortly to confinn a tentatively scheduled NRC inspection at INRYC0 in June,1981, during which Vendor Inspection 3 ranch management will be in attendance.
Objective evidence will be requested from INRYC0 at that time, to support the contentions made pertaining to NRC
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inspector attitudes raised in your response.
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T Please provide.the' requested additional inibrmation within 25 days from the
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date of this letter in order that we may complete our review.
Sincerely, W b
,,Karl' V. Seyfrit Director I
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