ML20031G597
| ML20031G597 | |
| Person / Time | |
|---|---|
| Issue date: | 09/21/1981 |
| From: | Oller R, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031G596 | List: |
| References | |
| REF-QA-99900323 TAC-10427, NUDOCS 8110230329 | |
| Download: ML20031G597 (13) | |
Text
O,RGANIZATION:
CONAX CORPORAT10N BUFFALO, NEW YORK REPORT NO.: 99900323/81-01 INSPECTION DATE(S): 8/10-13/81 INSPECTION ON-SITE HOURS: 25 CORRESPONDENCE ADDRESS: Conax Corporation ATTN: fir R. L. Duroure QA Manager 2300 Walden Avenue Buffalo, NY 14225 ORGANIZATION CONTACT:
Mr. R. L. Duroure, QA Manager TELEPHONE:
(716) 684-4500 PRINCIPAL PRODUCT:
Electrical Penetration Assemblies NUCLEAR INDUSTRY ACTIVITY:
The Conax nuclear product output is 45% of sales. The plant holds valid ASME "N" and "NPT" symbol authorizations.
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ASSIGNED INSPECTOR:
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R. E. Oller, Components Section (CS)
Date OTHER INSPECTOR (S):
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U.Potapovs,ActingChipf,CS Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B; and 10 CFR Part 21.
B.
SCOPE: Status of previous inspection findings; manuf acturing process i
control; change control; nonconformances and corrective action; and 10 CFR Part 21.
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8110230329 PDR GA999 E PDR 99900'J23
ORGANIZATION:
CONAX CORPORATION BUFFALO. NEW YORK REPORT NO.: 99900323/81-01 INSPECTION RESULTS:
PAG 2 of 6 A.
VIOLATIONS:
None B.
NONCONFORMANCES:
None C.
UNRESOLVED ITEMS:
None D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Deviation A (78-01): Contrary to Criterion IV of Appendix B to 10 CFR Part 50 and Nuclear QA Procedure No. 4.4, outgoing Purchase Order No. 51392 for safety-related items did not require the supplier to have a quality assurance program consistent with 10 CFR Part 50, Appendix B.
The NRC inspector verified that Conax has provided the following corrective and preventive actions in accordance with their response letter dated July 7, 1978. A Change Order No. 51392-1 was issued on July 14, 1978, to provide requirements that the applicable portions of Appendix B to 10 CFR Part 50 applied to the above P.O.
The Conax Purchase Specification No. IPS-30, Revision G was revised to include the QA program requirements of ANSI N45.2-1971 and 10 CFR Part 50, Appendix B; also, two Conax purchase orders issued in December 1980, were determined to include the requirements of IPS-30, Revision J.
Review of records of a meeting, dated June 9, 1978, between QA Manage-ment and reviewers of purchase requisitions confirmed that the reviewers were reindoctrinated concerning a more careful observance of the applica-tion of 10 CFR Part 50, Appendix B requirements in procurement of safety-related materials.
2.
(Closed) Deviation B (78-01): Contrary to Criterion IV of Appendix B to 10 CFR Part 50 and the Nuclear QA Procedure 4.2, the QA Manager had not initialed and dated the QA copy of four purchase orders to show his approval.
j The NRC inspector verified that Conax provided the following correc-tive and preventive actions in accordance with their response letter dated July 7, 1978. To clarify the original intent of procedure 4.2, paragraph 4.2.3 was revised on October 30, 1978, to provide that the QA Manager would review and approve by initialing purchase requisitions and purchase orders for Pressure Retaining Materials only. Review of a current P.O. No. N-66592, dated July 14, 1981, and the related pur-s chase requisition for pressure retaining material confirmed that both documents were reviewed and approved by the OA Manager.
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ORGANIZATION: CONAX CORPORATION BUFFALO, NEW YORK REPORT NO.: 99900323/81-01 INSPECTION RESULTS:
PAGE 3 of 6 3.
(Closed) Deviation C (78-01): Contrary to Criterion XII of Appendix B to 10 CFR Part 50; Nuclear QA Procedure No.12.1, and QC Instruction No. 29-2-9, a Ball Micrometer had not been etlibrated to the required frequency of six months.
~
The NRC inspector verified that Conax provided the following corrective and preventive actions in accordance with their letter dated July 7, 1978. Review by Conax during the previous inspecti n verified that the Ball Micrometer had been calibrated on schedule be~ the technician had failed to record the action on the Gage Calibration Card and affix a calibration label to this micrometer. During the previous inspection this micrometer was recalibrated, recorded, and labeled.
Review of other calibration records by Conax confirmed that none were deficient. During this NRC inspection review of records of a con-ference dated June 16, 1978, between the Calibration Technician and the QA Supervisor verified that the importance of accurate recording of calibration activities was reemphasized.
Review of the current calibration record for the Ball Micrometer verified that accurate records are being maintained.
4.
(Closed) Deviation D (7E-01):
Contrary to Criterion XV of Appendix B to 10 CFR Part 50 and the Nuclear QA Procedure No.15.3, Material Disposition Reports were not affixed to four header plate parts in the " Nuclear Storage Area-Nonconforming."
The NRC inspector verified that Conax provided the following corrective and preventive actions in accordance with their response letter dated July 7, 1978. When Procedure 15.3 was written Conax had not considered that the MDRs could not be readily attached to certain items, so to accomodate the exceptions, the procedure was revised on October 30, 1978, to provide for affixing a Reject Tag, with the MDR number on it, to items to which an MDR could not be attached. During the inspection the NRC inspector observed, in the nonconforming hold area, that a
" Feed Through Tube" and a "' ' der Plate" had attached Reject Tags containing MDR numbers i of attached MDRs.
5.
(Closed) Deviation E (78-01): Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and the QC Instruction 18.1, records dated January 3, 14, and March 1,1977 of the Lead Auditor-Auditor qualification had not been updated annually.
The NRC inspector verified that Conax provided the following corrective and preventive actions in accordance with their response letter dated July 7, 1978. On May 18, 1978, all auditor records were updated and a follow-up system using a "QA Follow-Up Log" was established to assure that auditor reviews were performed on time.
Review during this inspec-tion verified that Lead Auditor annual evaluations were performed on January 3, 1978, May 18, 1978, April 15, 1980, and april 10, 1981.
The annual auditor evaluations were performed on January.4,1977, May 17, 1978, May 7,1979, April 15,1980, and April 20, 1981.
Log entries
ORGANIZATION: CONAX CORPORATION BUFFALO, NEW YORK REPORT NO.: 99900323/81-01 INSPECTION RESULTS:
PAGE 4 of 6 indicated that the Lead Auditor and Auditor annual evaluations were due on April 11, 1982.
l 6.
(Closed) Deviation F (78-01):
Contrary to Criterion VI of Appendix B to 10 CFR Part 50 and the Nuclear QA Procedure No. 8.4, limited changes on travelers for two different parts, had not been initialed and approved by the QA Engineer.
The NRC inspector verified that Conax provided the following corrective and preventive actions in accordance with their letter dated July 7, 1978. The two subject travelers, involving limited changes, were re-processcd to the QA Engineer who reviewed, approved, and initialed them. The Plant Manager held training sessions on June 6,1978, and June 20, 1978, for Engineering Production Personnel and Manufacturing Personnel covering the applicable sections of the QA Manual and specifically NQA Procedure 8.4.5 covering the use of the Operation and Inspection Record System (travelers). These meetings were dicu-mented in the Plant Manager's memorandum dated July 5,1978, to the QA Manager.
7.
(Closed) Deviation G (78-01): Contrary to Criterion b of Appendix B to 10 CFR Part 50 and Engineering Instruction Nuclear No. 5.1, a person other than the designated Design Supervisor had signed the " check" space of Engineering Order No. N-0694.
The NRC inspector verified that Conax provided the following correc-tive and preventive actions in accordance with their response letter dated July 7,1978. Conax had decided that since the Design Supervisor initiated the EOs, that in accordance with good engineering practice, he should not check his own work. Therefore, the Job Engineer was assigned the role of checker. To accomodate this change in practice, paragraph 8.2.2.3 of the EIN No. 5.1 was revised on July 7,1978, to provide that the Design Supervisor or his designee would check drawings and EOs for compliance with requested changes, sign or initial the " check" block, and date the E0.
Review of EO No. N-0702 Change A, dated July 13, 1978, verified compliance with the revised EIN.
8.
(Closed) Deviation H (78-01): Contrary to Criterion VI of Appendix B to 10 CFR Part 50 and Engineering Instruction No. 5.1.1, appropriate approval signatures had not been entered on Engineering Orders Nos.
N-0679 and N-0702 for IPS Documents No. 267 and 333, respectively.
The NRC inspector verified that Conax had provided the following corrective and preventive actions in accordance with their response letter dated July 7,1978. Conax reissued EOs No. N-0679 and No. N-0702 on July 13, 1978, and obtained the signatures required by EIN-5.1.1.
A meeting was held on July 5,1978, at which the Chief Engineer, the Document Supervisior, and the Documentation Clerk were reinstructed concerning meeting the requirements of EIN-5.1.1.
ORGANIZATION:
CONAX CORPORATION BUFFALO, NEW YORK REPORT NO.:
99900323/81-01 INSPECTION RESULTS:
PAGE 5 of 6 9.
(Closed) Deviation I (78-01): Contrary to Criterion III of Appendix B to 10 CFR Part 50 and the Nuclear QA Procedure No. 5.1, the " Pressure Boundry" block on the Engineering Change Order (ECO) was being checked automatically when the hardware contained pressure boundry material and not after a review of the Stress Report.
- The NRC inspector verified that Conax provided the following corrective and preventive actions in accordance with their response letter dated July 7, 1978. To provide corrective action effective May 22, 1978, Conax rechecked ail ECOs, isst.ed since September 20, 1977, for s
compliance with the requirements of paragraph 5.1.6 of NQA Procedure No. 5.1 and reissued them after review of the Stress Reports where pressure boundry materials were involved. On July 11, 1978, the Nuclear Chief Engineer issued a directive to the Job Engineers, directing that the Pressure Retaining Material block on the E0s should be checked only after review of the Stress Reports to determine if changes affected the Stress Report. Review, during this inspection of ECN No. N-1564 dated July 31,1981 (formally ECO), verified that it contained a statement "Does rot affect the Design Report" as evidence of review, and it was properly signed.
lu.
(Closed) Unresolve; Item (78-01):
Procedures require that the Job Engineers review, approve, and initial purchase requisitions (PR) for materials.
It appears that several prs were initialed by Job Engineers in the " Requested By" space instead of the " Approved By" space. The vendor indicated action would be taken to resolve this matter.
The NRC inspector verified that the " Approval" blocks on purchase requisitions have been cnanged to identify the approval position as Engineer / Supervisor. The " Requested By" block is now separate. This latter block is completed by ProdJction Control.
E.
OTHER FINDINGS OR COMMENTS:
1.
Manufacturing Process Control This area of the inspection was accomplished by: review of nine QA Manual-Nuclear QA crocecures; examir.ation of three Operation and Inspection Record travelers in the machine shop for various parts, two Nuclear 0&IR travelers for penetrations being assembled, and two Nuclear 0&IR travelers for completed and shipped penetrations; examination of the documents in a traveler package prior tc release to manufacture; review of the " Material Traceability Log" for five different Penetration Sub-assemblies identified by Serial Numbers; review of three Conax customers Purchase Order Specifications; review of two Conax manufacturing proce-dures for the Vogtle Units 1 and 2 work, and observations of in-process parts and penetration assemblies.
No nonconformances or unresolved items we e identifed in this area.
I
ORGANIZATION:
CONAX CORPORAT10N BUFFALO, NEW YORK REPORT NO.: 99900323/81-01 INSPECTION RESULTS:
PAGE 6 of 6 2.
Change Control This area of the inspection was accomplished by:
review of seven QA Manual-NQA Procedures; review of a Conax customer purchase order and change order, Conax documentation check list, a Conax drawing, and its revision, and an engineer order, all for the Palo Verde work; review of a Conax purchase requisition and the related purchase order, and changes to these two documents. No nonconformances or unresolved items were identified in this area.
3.
Nonconfomances and Corrective Action This area of the inspection was accomplished by:
review of five QA Manual-NQA Procedures; observation of the locked room used for segrega-tion of nonconforming material and the items therein; review of 16 current completed Material Deficiency Reports; review of four MDRs involving corrective action requests by the QA Manager to manufacturing departments, and two MDRs involving corrective action requests to subvendors; review of the QA Manager's Corrective Action Follow-up on MDR's system for internal delayed responses to CAP.s, the QA Manager's Monthly Report on delayed MDR response, and notes of a monthly corrective action meeting between the QA Manager and the Plant Manager covering MDRs and other topics. No nonconformances or unresolved items were identified in this area.
4.
This area of the inspection was accomplished by: observation of the posted documents required by 10 CFR Part 21 and review of QA Manual-NQA No.1.5 covering reporting of defects and noncompliances under 10 CFR Part 21. No violations were identified in this area.
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