ML20135E453

Notice of Nonconformance from Insp on 961112-14 & 970128-30. Nonconformance/Deviation Noted:Failure to Ref or Include Mill Heat Analysis as Identified Attachment & Failure to Ref Mill Heat Analysis or Certification for Heat Treatment

ML20135E453
Person / Time
Issue date:	03/04/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20135E441	List: ML20135E438 ML20135E443 ML20135E453 ML20135E463
References
REF-QA-99901307 99901307-96-01, 99901307-96-1, NUDOCS 9703070080
Download: ML20135E453 (4)

Text

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NOTICE OF NONCONFORMANCE 1 ACCUTECH Division of B&G Mfg. Co.,Inc. Docket No.: 99901307 Las Vegas, Nevada Based on the results of an inspection conducted on November 12 through 14, 1996, and January 28 through 30, 1997, 1996, it appears that certain of your activities were not conducted in accordance with NRC requirements.

A. Criterion VII, " Control of Purchased Material, Equipment, and  ;

Services,"of Appendix B to 10 CFR Part 50, requires,in part, that  !

measures shall be established to assure that purchased material conforms to procurement documents.

Paragraph NCA-3862.l(b) of Section III af the ASME Code states that "When required chemical analyses (including mill heat analysis), heat I treatment, tests, examinations, or repairs are subcontracted, the '

approved supplier's certification for the operations performed shall be furnished as an identified attachment to the Certified Material Test l Report." '

i Paragraph NCA-3853.3(a) of Section III of the ASME Code states that the  ;

Materials Organization shall be responsible for establishing and  !

' verifying that the suppliers controls applicable to the activities I performed are adequate by surveying and auditing the supplier's established quality program which is consistent with the requirements of this Subarticle or having the supplier perform the activities with controls established by the Material Organization's program.

The following four examples demonsrate ACCTECH's failure to comply with the requirements and consitute Nonconformamce 99901307/96-01-03.

1. Contrary to the above, ACCUTECH's Certified Material Test Report (CMTR) for material supplied to PECO Energy Company (PECO) under Purchase Order (P0) LS 605919, dated January 18, 1996, certified that this material was supplied in accordance with their ASME Quality Systems Certificate (QSC), but did not reference or include the mill heat analysis as an identified attachment.

2. Contrary to the above, ACCUTECH's CMTR for material supplied to PEC0 under P0 LS 607801, dated March 3, 1996, certified that this material was supplied in accordance with their QSC, but did not include or reference the mill heat analysis or certification for heat treatment performed by an approved supplier as identified attachments.

3. Contrary to the above, ACCUTECH's CMTRs for material supplied to Consumers Power Company under P0 G 0183280, dated December 7, 1995, and to Entergy under P0 MP 96LO93, dated November 8,1995, certified that the material was supplied under their QSC, but did not include or reference reports of mill heat analysis or mechanical testing performed by approved suppliers. Additionally, documentation for 9703070000 970304 PDR GA999 ENVBGMFG 99901307 PDR i J

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this material did not verify that all tests required to be performed l (Macroetch) had been completed.

4. Contrary to the above, for material described in 3, above, ACCUTECH j could not provide documentation that organizations supplying this material had quality assurance programs that complied with the ,

requirements of NCA 3800 or with controls established under ACCUTECH's program.

B. Criterion VII, " Control of Purchased Material, Equipment, and Services,"

of Appendix B to 10 CFR Part 50, requires,in part, that measures shall be established to assure that purchased material conforms to procurement documents.

Paragraph 6.1 of ACCUTECH's Quality Systems Manual assigns to QA Department the responsibility for work order review prior to certification and states that, as a minimum, this review shall include verification that customer P0 requirements are met and the material conforms to the specification requirements.

Contrary to the above, ACCUTECH's QA Department did not provide adequate verification that material supplied to PEC0 under their P0 LS 606821, dated February 15,1996, and to Wisconsin Electric Power Co. under their P0 4500021861, dated November 1, 1996, complied with the P0 requirements. Specifically, ACCUTECH could not demonstrate that the suppliers of this material had been surveyed and audited to verify their conformance with the applicable provisions of 10 CFR, Appendix B.

Although ACCUTECH performed limited physical testing of this material, the sampling plan used for this testing did not have a documented basis to demonstrate that the material supplied under these P0s was equivalent to material purchased from suppliers qualified under the requirements of Appendix B. (Nonconformance 99901307/96-01-04).

C. Criterion XVI, " Corrective Action" of Appendix B to Part 50 states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies,, deviations, defective material, and equipment,and nonconformances are promptly identified and corrected. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."

ACCUTECH Standard Operating Procedure (S0P) 17.001, " Corrective Action," l Revision 5, dated November 15, 1995, states, in part, in Section 3.1 l that a failure of the QA program to comply with an approved regulation or commitment (ASME, ASTM, ANSI, MIL-STD etc.), is one of the conditions considered as adverse to quality. Section 3.2 states that conditions adverse to quality may be identified during an Internal Audit, ,

Management Audit, Supplier Audit or by other means. Section 3.3 states j that the' individual (usually a Lead Auditor or Auditor) identifying what appears to be a condition adverse to quality shall initiate a Corrective Action Report (CAR).

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Contrary to the above, ACCUTECH failed to identify two nonconformances described in NRC Inspection Report No. 99901076/94-01, i.e. failures to 4

comply with a regulation (10 CFR 50, Appendix B), as conditions adverse to quality and did not enter them in the corrective action process by initiating a CAR. Although these nonconformances were issued to Cardinal Industrial Products, corrective actions, including correspondence between ACCUTECH and NRC, continued after ACCUTECH's

' acquisition of Cardinal Industrial Products. (Nonconformance 99901307/96-01-05)

D. Criterion V, " Instructions, Procedures, and Drawings," of Appendix B to 10 CFR 50, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and that such activities be accomplished in accordance with these instructions, procedures, or drawings.

ACCUTECH Quality System Manual Section 22.0, " Interface Activities for Material and Associated Documentation Which Has Been Legally Transferred From Cardinal Industrial Products Corporation (CIPC) to ACCUTECH.

(Note: This material has not been removed from the warehouse facilities or control of ACCUTECH's Quality Assurance Department)," Revision 0, dated November 29, 1995, states, in Section 22.6, that ACCUTECH record packages shall contain CIPC documentation used to justify acceptance of the material.

Standard Operating Procedure (SOP) 22.001, " Transference of Material and .

Associated Documentation Between CIPC and ACCUTECH," Revision 2, dated November 15, 1995, states, in part, in Section 1.1 that the purpose of '

the procedure is to " ensure that ACCUTECH materials and documents are properly reviewed and approved prior to acceptance and use by ACCUTECH as Code and safety-related materials." Section 2.2 requires evidence of document review to be recorded on a " Document Review Checklist" form for each ACCUTECH P.O. item reviewed.

Contrary to the above, no documentation existed to verify that ACCUTECH had implemented the requirements of S0P 22.001 since July 1995 and had ensured that material and documents were properly reviewed and approved ,

, before material acquired from Cardinal Industrial Products warehouse

stock was sold to utilities as ASME Code or safety-related 10 CFR 50, Appendix B. (Nonconformance 99901307/96-01-06)

E. Criterion V, " Procedures,' of 10 CFR Part 50, Appendix B, requires in

, part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the

':ircumstances and shall be accomplished in accordance with these instructions procedures, or drawings l

ACCUTECH Standard Operating Procedure (S0P) 17.002, " Reporting of Defects and Noncompliance," Revision 6, dated November 15, 1995,

. requires the documentation of 10 CFR Part 21 evaluations on S0P Form 4 17.2. >

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Contrary to the above, ACCUTECH did not document the evaluation of heat lot K7, on form CF 17.2, in accordance with the requirements of ACCUTECH SOP 17.002.(99901307/96-01-07)

Please provide a written statement or explanation to the U.S. Nuclear  ;

Regulatcry Commission, ATTN: Document Control Desk, Washington, D.C. 20555, '

with a copy to the Chief, Special Inspection Branch, Division of Inspection and Support Programs, Office of Nuclear Reactor Regulation, within 30 days of 3 the date of the letter transmitting this Notice of Nonconformance. This reply )

should be clearly marked as a " Reply to a Notice of Nonconformance" and should i include for each nonconformance: (1) a description of steps that have been or  !

will be taken to correct these items; (2) a description of steps that have  ;

been or will be.taken to prevent recurrence; and (3) the dates your corrective  ;

actions and preventive measures were or will be completed.

Dated at Rockville, Maryland this 4th day of March 1997