ML20137C473

Notice of Nonconformance from Insp on 850916-20 & 23-27

ML20137C473
Person / Time
Issue date:	01/14/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20137C464	List: ML20137C461 ML20137C473 ML20137C527
References
REF-QA-99901025 99901025-85-01, 99901025-85-1, NUDOCS 8601160329
Download: ML20137C473 (3)

Text

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APPENDIX A General Nuclear Systems Docket No.- 99901025/85-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC . inspection conducted on September 16-20 and 23-27,

.1985, it appears that certain GNS activities were not conducted in accordance with NRC requirements.

Criterion-V of Appendix B to 10 'CFR Part 50 states: " Activities affecting quality shall be prescribed by documented instruction, procedures, or drawings, 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:

1. -Section 3.2 of GNS Procedure No. PV 97 " Procedure for Notifying US NRC or.

Customer.of Defects and/or Noncompliances per US 10 CFR Part 21" dated June 22, 1984, requires that each Purchase Order (P0) for nuclear jobs specify that the provisions of 10 CFR Part 21 apply.

Section 4.3.1 of GNS's Quality Assurance Handbook (QAH) dated December 20, 1984 requires that the Purchase Requisition specify quality requirements.

Section 4.3.2 of the OAH states-in part: "The Purchase Requisition...shall contain the following information...M. Whether or not 10 CFR Part 21

. applies..."

Section 4.3.4'of the QAH requires that the P0 contain all the information supplied on QA approved Purchase Pequisitions.

Contrary to the above, a review of nine P0s to subcontractors for items and services pertaining to the CASTOR V casks for Virginia Electric & Power Company -(VEPC) did not specify that' the manufacturing activity should be conducted under an approved QA Program and did not specify that the requirements of 10 CFR Part 21 applied (85-01-01). The nine subcontractors were Gontermann & Pipers and Siempelkamp (cast body), Butting Metallwerk (fuel basket), Boschgotthnardshutte (forged lids and trunnions), Schmidt &

Clemens (fasteners), Cefilac (metallic seals), Pennekamp Huesker (neutron moderator material), Von-Roll (nickel' plating), and Kraftwerk Union (final machining and assembly).

I B601160329 860114 PDR GA999 EECGENS 99901025 PDR t

2. Section -18.2.1 of the QAH requires that subcontractor's QA Programs be audited at least annually during the interval in which material or services are being controlled.

Section 18.2.2 of the QAH reqJires that audits be performed with written procedures or checklists by qualified personnel.

Section 18.3.1 of the QAH states in part: " Audits shall be conducted using a checklist..."

Section 17.3 of the QAH requires that Personnel Qualification Records be retained for three years.

Contrary to the above, a review of six external audit reports and 0A records pertaining to personnel qualifications revealed the following (85-01-02): ,

a) Audits of three subcontractors were overdue, in that, during the interval in which material / services were being controlled, the most recent audits of Butting Metallwerk and Kraftwork Union (KWU) were in July 1984 and Siempelkamp in September 11, 1984.

b) Checklists were not used in any of the six audit reports reviewed.

c) Qualifications of the auditing personnel were not documented and retained as QA records.

3. Section 5.1.1 of the QAH requires that procedures include or reference quantitative and qualitative acceptance criteria for prescribed activities.

Contrary to the above, a review of GNS Procedure No. 91 " Hydrostatic Test Procedure for Dry Spent Fuel Storage Cask" dated October 23, 1984, and GHS Prnceduro Nn, PV 3?-l "Holium Ipak Test Procedure for Dry Spent Fuel Storage Cask" dated June 28, 1984 revealed that neither procedure referenced

.the requirement for the sequence of tightening bolts, the tightening torque and subsequent documentation on a test report (85-01-03).

4. Section 9.3.1 of QAH requires that NDE personnel be qualified in accordance with the recommended practice of the German Association for Nondestructive Testing (DGZP) and/or the American Society of Nondestructive Testing SNT-TC-1A.

A letter dated June 13, 1984, from the DGZP to the QA Manager of GNS states that the reouirements of the " Recommendation for the Qualification and Certification of NDT Personnel" of the DGZP are equivalent to SNT-TC-1A.

SNT-TC-1A, June 1980 Edition, requires that GNS establish a written practice for the control and administration of NDT personnel training, examination, and certification; and that qualification records of the certified individuals be maintained by GNS and include the following:

eye examinations for the period of certification, current copy (s) of the written examinations, personnel certifications, and a statement indicating satisfactory completion of training in accordance with a written procedure.

Contrary to the above, a review of records for four NDT personnel (Nos. 2, 6, 7, and 9) revealed the following (85-01-04):

a) GNS did not have a written practice or procedure for the various disciplines of NDT b) Eye examinations and current copies of written examinations were not maintained on file for the four examiners ,

c) Certifications for Level II ultrasonic testing (examiner No. 7) and for Level II leak testing (examiner No. 9) were missing d) Statements indicating satisfactory completion of training were missing for the four examiners

5. Section 4.5 of GNS Procedure No. 32-1 for helium leak testing requires that each test gauge be calibrated against a calibrated master gauge or an internal calibration standard prior to and after each test.

Section 5.5 of GNS Procedure No. 91 for hydrostatic testing requires that each test gauge be calibrated against a calibrated master gauge prior to and after each test.

Section 5.7 of GNS Procedure No. 91 requires that the master gauge be calibrated periodically.

Contrary to the above, witnessing of testing conducted on September 17 and 18, 1985, and a review of calibration records at GNS and KWU revealed the following (85-01-05):

a) Pressure gauge No. 6 which was used for the leak test did not have a calibration sticker, and there was no evidence of records to show that the gauge was calibrated.

b) Pressure gauge S/N 31 which was used for the hydrostatic test was last calibrated in October 1984 by KWU. When this anomaly was identified during the inspection, the gauge was calibrated by KWU on September 20, 1985, but calibration records for the dead weight tester used to calibrate the gauge were noted to be missing after April 1982.

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