ML20055B113
| ML20055B113 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20055B087 | List: |
| References | |
| REF-QA-99900733 NUDOCS 8207200372 | |
| Download: ML20055B113 (4) | |
Text
. - -. -
APPENDIX A American Warming and Ventilating Inc.
Docket No. 99900733/82-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on April 26-30, 1982, 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 accom-plished in accordance with these instructions, procedures or drawings.
Instructions, procedures, or drawings shall include appropriate quantita-tive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Nonconformances with these requirements are as follows:
A.
Paragraph 1.1, its subparagraph 1.1.1, and paragraph 1.2 of Quality Assurance Section No. S-300, Revision 1, dated November 27, 1974, require that all inspection tools: (1) be individually serialized; (2) have a tool inspection history card; and (3) bear a calibration status label on the equipment or on its container.
Revision 4 of the Quality Control Calibration Schedule, dated October 16, 1981, added wire crimpers.
Contrary to the above, wire crimper, No. 59170, Model AH, located at the Waldron facility had not been included in the calibration schedule as evidenced by the lack of: (1) its serialization; (2) a tool inspection history card; and (3) a calibration status label.
B.
Quality Assurance Procedure No. P-180, Revision 2, dated November 21, 1980, contains the following requirements:
1.
Paragraph 7.1.2 states, "For changes to plant originated Fabrication Instructions the plant writeup and Q.C. Personnel shall be responsible for the issue of revised documents and the removal of voided documents."
I l
8207200372 820701 PDR GA999 EMVAMERW 99900733 PDR 1
i
-,---,n
. 2.
Paragraph 7.2.5 states, "Q.A. document revisions shall be transmitted internally via a Q.A. Department interoffice memo and all voided documents shall be returned, recorded and destroyed (with the exception of one copy kept for record)."
3.
Paragraph 8.1 and its subparagraph 8.1.2, state in part, "Immediate changes that are verbally requested and approved shall be indicated on the subject document... A written con-firmation of approval via ECN (Engineering Change Notice) or Q.A.I.0.M. (Quality Assurance Interoffice Memo) shall be transmitted within a 2-day period."
Contrary to the above:
a.
Removal of voided documents had not been accomplished at the Waldron plant, as evidenced by the inclusion of superseded sheets in the Fabrication Instructions for American Warming and Ventilating Job No. 90247.
For example, the Fabrication Instructions included: (1) page 1 of 11 and 1 of 12, dated March 7, 1980, and March 4, 1982, respectively; (2) two pages 3 of 12, one dated March 4, 1982, and the other, April 8,1982.
b.
The voided copy of QA Section No. S-100 (Revision 2, dated August 1, 1979) at the Waldron plant had not been returned, recorded and destroyed, as evidenced by its presence in the QA Manual.
The latest document was Revision 3, dated April 19, 1982 (latest approval date).
The QA Manual at the Waldron plant did include other documents that had been revised as late as April 19, 1982.
c.
A written confirmation of approval, via ECN or QAIOM, had not been transmitted within a 2-day period for the verbally requested and approved changes made to the following drawings on February 26, 1982:
(1) 15716, Revision B, dated December 21, 1981; and (2) 15717, Revision B, dated December 21, 1981.
The drawings were located at the Waldron plant and were for job No. 90247.
C.
Paragraph 4.1, and its subparagraphs 4.1.1, 4.1.2, and 4.1.3, of Engineering Procedure No. EP1225, Revision 1, dated December 26, 1979 (approved June 12, 1980) states, " Drawing revision letters are recorded on the backside of the appropriate drawing number card listing the following information:
Revision letter Revision date Revised by (initials)."
. Contrary tc the above, " revised by" information (initials) had not been recorded on the reverse side of the drawing number card for Revision C, dated April 25, 1982, of Drawing No. 80343-009-000.
D.
Note 8 on drawing 14441-201, Revision H, dated October 5, 1981, states, "The electrical conduit connection at the NAMC0 limit switch is sealed with EH 459-20000 Thread Sealant Kit supplied by NAMCO (Procedure No. EH459-20000)."
Contrary to the above: (1) NAMC0 Thread Sealant Kit EH 459-20000 was not used to seal the electrical conduit of a NAMC0 Snap-Lock Limit Switch (EA 18031302) installed on a Hope Creek generating station backdraft isolation damper (Shop Order No. 90192/WQT/650); and (2) NAMCO Procedure No. EH 459-20000 was not available for use during installation of the above kit at the Waldron facility.
E.
Paragraph 1.2.of QA Section No. 5-140, Revision 2, dated October 5, 1977, states in part:
" Product recommendations... are translated into specific American Warming and Ventilating (AW) design documents by Design Technicians."
Step 7 of NAMCO Installation Instruction EA18990006 states, " Torque top cover screws in a staggered pattern to 20 in. pounds."
Contrary to the above, Design Technicians had not translated NAMC0 product recommendations into specific AW design documents with respect to torquing of cover screws for a switch installed on a Hope Creek generating station backdraft isolation damper (AW Shop Order No. 90192/WQT/650).
F.
Paragraph 4.2 of QA Procedure No. P-361, Revision 0, dated February 6, 1979, states, "The Quality Assurance Manager shall issue a report on the defect and/or deviation and request an evaluation in writing from the Corporate President, Vice-Presidents of Manufacturing and Engineering and the Nuclear Engineering Manager.
The Quality Assurance Manager shall also initiate a written evaluation."
Contrary to the above, a report and a written evaluation had not been initiatea in the case of the following known defect / deviations:
1.
An AW (February 6, 1980) 10 CFR Part 21 notification to the NRC concerning ITT AH90 Series or NH90 Series Hydromotor Electro-hydraulic Actuator; 2.
An AW (May 6, 1980) 10 CFR Part 21 notification to the NRC con-cerning viring connection defects; and
. 3.
_The mounting tab and fusible link' fire damper deficiency identified by Mississippi Power and Light in their PRD-81/05 report, reported under 10 CFR Part 50.55(e).
.