ML20140E488

Notice of Nonconformance from Insp on 841112-15

ML20140E488
Person / Time
Issue date:	01/09/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20140E478	List: ML20140E475 ML20140E483 ML20140E488 ML20140E494
References
REF-QA-99900888 NUDOCS 8501110053
Download: ML20140E488 (4)

Text

-

APPENDIX B Texas Bolt Company Docket No. 999Q(L8.88/84-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on November 12-15, 1984, it appears that certain of your 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 instructions, 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:

A.

Section 1.7 of the Quality System Maual (QSM), Revision 7 states, in part,

" Qualification of personnel performing and interpreting non destructive examinations... will be qualified in accordance with ASME S6ction III and SNT-TC-1A.

Section 9.2.3 of SNT-TC-1A (June 1975 Edition) states, "The employer shall in his written practice establish rules covering the duration of interrupted services which will require re-examination and re-certification.

Section 9.6 of SNT-TC-1A states, in part, " Certification records shall be maintained on file by the employer and should contain personnel records of the certified individuals...."

Section 9.6.1 of SNT-TC-1A states, in part, "The personnel records of the certified individuals should include as a minimum the following:

... d.

Statement indicating satisfactory completion of training in accordance with the employer's written procedure.

e.

Results of the physical examination...

f.

Copies of current examinations...."

Section 8.5.3(c) of SNT-TC-1A requires that the practical examination for a Level III include the writing of a specification or procedure fo* the

- performance of the applicable nondestructive test.

Centrary to the above, a review of nondestructive examination (NDE) records revealed the following:

(1). Procedure No. TB-NDT-PQC-#1, "NDT Personnel Qualification & Certi-fication" dated March 2, 1981, did not contain rules covering

. interrupted service requiring re-examination and re-certification.

EkV

6 2-(2) Records for five NDE personnel (3-Level II and 2-Level III) from TexasTolt (TB) did not contain a statement indicating completion i

. of-training in accordance with TB's written procedure.

(3) were certified as Level III-liquid penetrant -(PT)pection (II), who Records for two-NDE personnel from Industrial Ins and Level II-magnetic particle (MT), did not contain a physical' examination (s) or copies of the PT or MT examinations.

4

~

(4) The practical examination for both of TB's Level III-MT examiners (QA/QC Manager and Assistant QA/QC Manager) were incomplete in that

.a specification or procedure for the performance of a MT examination was not written.

4 B.

The Policy Statement of the QSM states, in part, "... Texas Bolt Company Quality System to comply with the quality program criteria set forth in ASME Section III Sub-section NCA-3800 and ANSI N45.2...."

Subsection NCA-3866.2 of Section III, the ASME Code states, in part,

"... measures shall assure that documents including changes, are

= reviewed for adequacy... by authorized personnel...."

Section 7 of. ANSI /ASME N45.2-1977, "QA Program Requirements for Nuclear Facilities" states.-in part, " Document control measures shall provide for:

(1). identification o.f individuals or organizations responsible for preparing, reviewing, approving... documents and revisions thereto...."

Contrary to the above, measures were not in place to identify individuals /

organizations responsible for preparing, reviewing and ' approving the procedures contained in;the Procedure Manual.

C.

Section 4.3 of the QSM states, in part, " Purchase of... services will be from the approved vendors list."

Section 7.lb of the QSM states "Only supplier's (sic) approved for use-by the Quality System department will be utilized."

Contrary to the above, a review of purchase orders (P0) ~to suppliers and-

~

external audits conducted by'TB revealed that the plating services of Southwestern Plating were utilized in September 1984 on nuclear bolts, and the calibration-services of Honeywell Corporation, W. H. Kessler Company, and Newport Instrument. Company were utilized for quality-related, temperature measuring equipment on November, June, and May 1984,

.respectively, although none of these firms were included on the approved vendors list.'

t:

3

+

..,3

.~

.*-,c.~,.

4m,

,,w..._-

.%~,.

4m,,

~..

. D.

Section 12.1 of the QSM states, in part, " Calibrations are traceable to National Standards...."

~

Subsection NCA-3868.1 of Section III of the ASME Code states, in part,

" Calibration shall be against measurement standards which have known relationship to national standards...."

Section 13 of ANSI /ASME N45.2-1977 states, in part, "... inspection, measuring, and test equipment shall be... calibrated... against certified equipment having known valid relationships to nationally recognized standards."

Contrary to the above, II calibrated two magnaflux units'(S/N 43253 and S/N 81409) but II's Machinery Inspection Report for each unit did not indicate the standards used for calibration to assure that traceability to national standards was maintained.

E.

Section 5.1 of the QSM states, in part, " Published instructions and procedures are utilized to assure that activities affecting quality are controlled."

Sections 2 and 6 of ANSI /ASME N45.2-1977 require that activities affecting quality be prescribed and accomplished in accordance with written instruc-tions or procedures.

Subsection NCA-3866.4 of Section III of the ASME Code states, in part,

" Measures shall be established to assure that processes including heat treating are controlled...."

Subsection NCA-3866.1 states, in part, "... maintain a written description of the procedures... for control of quality...."

Contrary to the above, it was noted that procedures or instructions did not exist for the following activities:

Heat treating in the Electric Box Furnace (S/N F-10-65).

Material testing such as tensile strength,-hardness, and proof loading evaluations.

Utilization of stamps such as " LAB," " NUCLEAR," and " Material l

Approved by Met Lab."

F.

Section 4.2 of the QSM states, "The Quality Systems Manager, or his designee, will review and sign each purchase order and changes for nuclear materials or services. This review will assure that the requirements of the codes or additional customer requirements, that pertain to materials or services, are satisfied."

~

L

. Contrary to the above, the Quality System Manager or his designee did not sign a'lotal of 19 internal purchase order forms reviewed during the inspection.

G.

Section 12.5 of the QSM states " Discrepant gauges are separated and placed under lock and key. These gauges are also tagged with a "00 NOT USE" tag.

Contrary to the above, on November 14, 1984, numerous discrepant gauges including a "no-go" gauge and a micrometer were not placed under lock and key and were not tagged with a "D0 NOT USE" tag.

I H.

Section 15.2 of the QSM states, in part, "At discovery, material evaluated to be nonconforming shall be properly identified and tagged.

Segregation of material will be accomplished as necessary to prevent mix (SIC) with acceptable material and maintained until proper disposi-tion has been made."

Contrary to the above, TB did not tag and segregate nonconforming material following final _ visual inspection as evidenced during a plant tour when bolts, nuts, and threaded rods were stored in untagged cartons which were mixed with cartons of acceptable materials pending final product packaging and shipment.

l I.

Section 15.2 of the QSM states, in part, "The Quality Systems Manager will determine disposition of nonconformances and indicate the remedial action to be taken for correction of the conditions reported."

Contrary to the above, three nonconformance reports for 1984 and three nonconformance reports for 1982, constituting the total number of reports for each year, were dispositioned by the Assistant Quality Systems Manager /

Laboratory Supervisor.

6 h

- _ - _ - _ - _ - _ _ - _ _ _ _ _ _ - - _ -