ML20041B394
| ML20041B394 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1982 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20041B388 | List: |
| References | |
| REF-QA-99900367 NUDOCS 8202230601 | |
| Download: ML20041B394 (3) | |
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APPENDIX A NOTICE OF NONCONFORMANCE Square D Company Power Equipment Division Docket No. 99900367/81-01 Based on the results of an NRC inspection conducted on November 30 -
December 4,1981, 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 draw-ings, of a type appropriate to the circumstances and shall be accomplished in accordance 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.
Quality Control Procedure No. 187, dated February 18, 1980, consists of a form with the same number.
It is considered to be self-explanatory and is to be completed during/after problem identification and investigation.
The lower portion of the form addresses reportability of the problem to the Nuclear Regulatory Commission.
Contrary to the above, the problem reportability portion of the form had not been completed for Problem Report No. 1980-2.
This related to the coating on rubber bumpers of Size 3 starters which was first reported on February 28, 1980.
B.
Paragraph 3.5 of the Corporate Quality Assurance Manual, dated May 16, 1978, states in part, " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...
Contrary to the above, design control measures commensurate with those of the original design had not.been performed for the field change which relo-cated units within the cabinets in order to eliminate the problem of pinched wires.
This was evidenced by the lack of documentation which would address the effect that unit relocation would have upon the seismic qualification of the motor control centers.
C.
Standard Practice Bulletin No. 512.406. dated December 6, 1976, contains the following requirements:
1.
Paragraph III.C, states in part, "Significant deficiencies in the program shall be recorded on an ' Audit Finding Report' This form shall also be used for noting resolution commitments and satis-factory implementation of corrective action."
0202230601 820122 PDR GA999 ENVSGUAR 99900367 PDR
=
. 2.
Paragraph IV states, " Corrective action for each finding shall be reviewed within sixty (60) calendar days of the audit date.
Docu-mentation of satisfactory corrective action implementation shall be recorded on the ' Audit Finding Report'."
Contrary to the above, corrective action for each finding had not been reviewed within 60 calendar days of the audit date of a QA program Audit conducted July 13 and 14,1978. The QA Audit Finding Report; (9) for the audit reflect dates of August 20, 21, 28, 1979, for satisfactory implemen-tation of corrective action (Corrective Action Implementation Audit).
D.
Paragraph III. B of Standard Practice Bulletin No. 512.307, dated November 10, 1977, states in part, " Complete the Routing Change Form No.
PE-1014... as described for the following type of Routing Changes."
Some of the changes are group, quantity, setup /run time, and sequence number.
Contrary to the above, Routing Change Form No. PE-1014 is not being used to change Master Record Routings.
Note:
The inspector was provided a document _ entitled, Operational Routing Manual, dated September 28, 1981, and informed that this manual is used to change Master Record Routings.
The inspector noted that the manual had not been approved and was informed that it is in the formative stage.
E.
Paragraph II.C of Standard Practice Bulletin No. 500.020, dated September 20, 1976, states, "The foreman of a particular special process area is responsible to see that the personnel performing the process are adequately trained to satisfactorily perform the special process to comply with the SPP [Special Process Procedure] and Quality Control requirements."
Paragraph 3 of Quality Control Procedure No. 200-9, Revision C, dated October 15, 1981, states in part, " Records shall be maintained which verify control over such factors as equipment settings, chemical tests, gauge reading, etc."
Contrary to the above: (a) personnel had not satisfactorily performed the electrocoat paint process to comply with Special Process Procedures No. B-1, dated October 12, 1977; and (b) records maintained on the electro-coat paint process did not verify control of equipment settings, chemical tests and gauge readings.
This was evidenced by the following examples:
Requirements
-Observed - 12/2/81 (late am)
Sta. No. 2, 140 - 180 F 128 F 4, 155 - 165 F 146 F 4
7, 13 - 15 PSI 20 PSI 13, 325 - 350 F 380 F 9, pH 8.2 - 9.0 (See notes below) 2, Free-Alkali 8.5 - 16.5 pts.
(See notes below) e-
-,-e
~.
n--
g v.
r
. Specit,1 Process Control Records, dated November 2-December 2, 1981, indicated that: (a) Sta. No. 2 varied from 132 to 158 F; (b) Sta. No. 4 varied from 138 tu 156*F; (c) Sta. No. 7 varied from 20-30 PSI; it was also noted that the record reflects a requirement of 15-20 PSI as opposed to the procedure; (d) Sta. No. 13 indicated 380*F; (e) Sta. No.
9 varied from 8.7 to 9.5 with 25 of 39 readings outside the requirements; and (f) Sta. No. 2 varied from 10.7 to 22.6, with 30 of 32 readings outside the requirements.
F.
Paragraph II.E and subparagraphs 1 and 4 of Standard Practice Bulletin No. 500.012, dated June 22, 1973, state in part, "When master drawings are removed from the master files, a reproducible copy must be filed in its place... An entry is made on the drawing location card of the date, holder and design notice number of the revision."
" Revision Marks.
Revision marks, consisting of the revision letter in a circle... shall be placed close to the point, part or line (one or more) that has been changed."
"Only the latest revision is to be marked.
Previous marks are to be removed."
Contrary to the above:
1.
An entry had not been made on the drawing location card (or a_ Repro-duction Services Request form) for Drawing No. D - 80103-005 which had been removed from the master file.
2.
Previous revision marks had not been removed from point, part or line of: Bills of Material, Nos. 30318-286-57 Revision A1, dated July 30,1979; 30322-407-58, Revision R, dated August 21, 1980; and Specification No. A-40004-013-01, Revision B, dated October 4, 1976.
G.
Paragraph II.B and subparagraphs 1 and 2 of Standard Practice Bulletin-No. 512.407, dated May 11, 1976, state in part, "The Peru Plant Quality Control Supervisor or his designate shall review each written Quality Control Procedure (QCP) at seast once annually.
"A record of QCP Reviews shall be maintained...."
Contrary to the above, neither the Peru Plant QC Supervisor, or his designate, had reviewed each written QCP annually; as evidenced by the lack of Records of QCP reviews.