ML20141K404

Informs That Wolf Creek Evaluated Ameron Response to Findings Identified During Audit Conducted on 970122-23 & 970128-31.Evaluation Found Responses to Findings Ron 01/97-001-011 Conditionally Accepted

ML20141K404
Person / Time
Site:	Wolf Creek
Issue date:	03/28/1997
From:	Krause T WOLF CREEK NUCLEAR OPERATING CORP.
To:	Lamb M AMERON
References
QS-97-0016, QS-97-16, NUDOCS 9705290076
Download: ML20141K404 (17)

Text

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W@ NUCLEAR OPERATING r

iF . CREEK March 28,1997 l

QS 97-0016 Ameron Protective Coating Group i1605 Vimy Ridge Road P.O. Box 192610 Little Rock, AR 72219 2610 Attention: Mr. Michael Lamb, Quality Assurance Manager

Subject:

Evaluation of Ameron Response to WCNOC/ Supplier Quality Audit Findings

Reference:

WCNOC Audit Report- A350-K002 Ameron Response - letter dated 2/27/97

Dear Mr. Lamb:

Wolf Creek Nuclear Operating Corporation / Supplier Quality has evaluated the Ameron response to the findings identified during the audit conducted 1/22-23/97 and 1/28-31/97.

The evaluation found that responses to findings RON 01/97-001 through 01/97-011 are conditionally accepted, with additional responses required for RON's 01/97-009 and 010 by 5/1/97. Below is a status of the findings and the ,

required action to be taken by Ameron.

RON NUMBER FINDING STATUS ACTION REQUIRED 01/97-001 Open Corrective action status update due $/1/97 01/97-002 Open Corrective action status update due 5/1/97 j 01/97-003 Open Corrective action status update due 5/1/97 l

01/97-004 Open Corrective action status update due 5/1/97 01/97-005 Open Corrective action status update due 5/1/97 01/97 006 Open Corrective action status update due 5/1/97 gggi, esa l

01/97-007 Open Corrective action status update due 5/1/97 Eis".

em 01/97-008 Open Additional response required by 5/1/97 to address whether W1041 " Purchase Orders will include the requirement to

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i l impose the calibration suppliers quality program and MIL STD 45662A or ANSI Z510 in Ameron purchase orders to g, calibration suppliers. g,

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01/97-009 Open Additional response required by 5/1/97 to address the i

frequency of audits. Also as stated in the original audit report, audits of Brookfield and Fluid Power must be conducted within six months our audit exit meeting.

Open Corrective action status update due 5/1/97 01/97-010_

Open Corrective action status update due 5/1/97 g 01/9311 I hh P. O. Box di t / Burhngton. KS 66839 / Pnone:(316) 364-8831

'a Equal Opportunity Employer M/F/HCNET 9705290076 970328 PDR ADOCK 05000482 (: .ggfd lP PDR

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QS 97-0016 As noted in the above table, a corrective action status update for all findings is due on 5/1/97. The updates are important to ensure that corrective action due dates are being met and implemented as required.

Should you have any questions about the evaluation, please contact me at (316)364-4156 or Mr. Vic Canales, Supervisor Supplier / Materials Quality at (316) 364 4214.

Sincerely,

[ s T:-'

Terry L. Krause Supplier Quality Specialist Ill

Attachment:

Ameron Response cc: V. J. Canales (AE SQ), w/o - NPRDS A350 File ,

J. D. Kitchens (AE PUR), w/o NUPIC Membership, w/a l W. B. Norton (CC-PIA), w/o N. S. Hawkins - NSRC (CC-PIA), w/o j D. G. Long (AE ME), w/o Vault (CC-DS), w/a i R. L. Traudt (CC DES), w/a Document Services (CC-DS), w/o l l

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February 27,1997 A

AMERON IN T E R N ATIO N A t, PaoTECTwa COAT 1Nos Gnour 1160s Vimy Ridge Rrad I.ittle Rock. Arkansas 72209 eg ause RO. Box 192610 Wolf Creek Nuclear Operating Corp uttle Pock. Arkansas 72219 2610 PO Box 411 Telephone: sols 4ss.4500 Burlington, Kansas 66839 Fax:50lI455 3061 Intemet: www.ameron. net.com E mail: wstoane@aol.com Terry:

Please find attached the Ameron International Protective Coatings Group response to the Noncompliance Reports initiated during your recent NUPIC audit ofour facilities. Please note that each Corrective Action has been assigned to a responsible manager and that each action has also been assigned a Target Completion date. A few of the Corrective Actions have already been implemented. However, several of the Corrective Actions will require some changes to the computer system and will not be implemented until the new, S2K computer system is up and running. This explains the lengthy time lines that have been defined for some of the Corrective Actioru.

If you have any questions or comments regarding the proposed Corrective Actions, please contact me immediately. Otherwise I will get in touch with you over the next couple of weeks.

Sincerely,

?.A.b, -

t licheal Lamb Quality Manager i

ec. K. Kolinek, J. Garnett, G. Smith, S. McKown, R. Gasmena, C. Stanley, H. Kline, S. Bosan, A. Warren, M. Jones du ..itI wpi, M. larnb,2/27/97, wrmon 1 t

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Page 1 RON NO: N/A RESPONSIBLE MANAGER: J. Garnett AUDITOR RECOMMENDATIONS AND CONCERNS

1) When raw materials are transferred from the original vendor bag into paper bags during the weigh out process, the auditors observed that several raw materials were transferred to unmarked bags and then the multiple unmarked bags were marked with the raw material codes. The auditors suggest that the bags should be marked prior to the transfer of raw materials to the bag to eliminate the possibility of a mix up later. This suggestion needs to be reflected in practice and procedure.

Target Comoletion Date: 4/30/97 l 2) Partial, open bags of raw materials are exposed to changes in l humidity accumulation and potential contamination. Ameron needs to address this problem with a corrective action. Potential corrective actions would include taping bags closed or putting the opened bags into plastic boxes that can be sealed closed.

Target Comoletion Date: 7131197

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RON NO: 01/97-001 RESPONSIBLE MANAGER (S): H. Kline, S. Bosan

1) Ameron needs to make sure that the " Certified Product Alert Notice" show up on the computer system for all of the " Nuclear products" Target Comoletion Date: 6/30/97 I

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2) A " sign-off" procedure needs to be instituted where the " authorized" approval of changes to Nuclear formulas includes a signature to a statement indicating that the current revised version of the formula has been reviewed and the indicated changes to the formula will not affect the essential characteristics / properties of the formula as it l

had been previously qualified for Nuclear applications. Sianature Qale Target Comoletion Date: 7/31/97

3) More inclusive documentation i.e.. test results cross referenced and indicated on the formula version history, as well as, some text explanation of the technical justification for the formula version l change. Not just and indication of the change that is being made but also some information as to why thct change is being made.

Target Comoletion Date: 7/31/97

4) 3366 and 3367 require back-tracking to make up the product definition / documentation of the product criteria on a Product j

Change Order or Development Criteria sheet.

Target Completion Date: 7/31/97 i .

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l ON NO: 01/97-001 Continued

5) The Auditors suggested setting up " master" Nuclear product files for l

each product so "all" the information pertaining to that product could i be more easily accessed during future NUPIC audits. I l

1 Target Completion Date: 6/30/97 1

I l 6) Review the following Work Instructions applicability and current

} application and revise accordingly-a) W1012 b) Wl015 c) Wl019 l d) W1020 l

! Taraet Completion Date:

6/30/97 l

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j Page 4 i RON NO: 01/97-002 RESPONSIBLE MANAGER (S): R. Gasmena, J. Garnett j S.McKown

1) Generate list of Critical / Non-critical raw materials used in Nuclear i batches. RG Target Comoletion Date: 2/25/97 Completed l l

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2) Establish procedure and responsibility to review this list for l l completeness and correctness on a periodic basis and when new,

! Nuclear grade formulas are added to the production mix. RG Target Comoletion Date: 6/30/97 l

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3) Determine in-coming raw material acceptance criteria for critical and ,

l non-critical raw materials: RG.  !

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a) Critical raw materials,100% lot tested by Ameron QC Taraet Comoletion Date: 2/25/97 Implemented b) Non-critical raw materials accepted by Certificate of Analysis from Vendor l

l Taraet Comoletion Date: 9/30/97 l

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ON NO: 01/97-002 Continued

4) Establish methodology for transferring " acceptance" requirements to a) Vendor's. (Utilize PO's to identify requirements for specific raw materials to the vendors.) SM Target Comoletion Date: 7/31/97 b) Ameron's in-coming Raw Material Receiving Personnel JG Taraet Comoletion Date: 7/31/97 l

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l RON NO: 01/97-003 RESPONSIBLE MANAGER (S): M. Lamb

1) Revise Section 1.0 of the Ameron Quality Manual to reflect the current Ameron International organizational status in text and charts. l l

l Taroet Comoletion Date: 5/15/97 l

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RON NO: 01/97-004 RESPONSIBLE MANAGER (S): R. Gasmena, M. Lamb

1) Contact B. Wilson to obtain a copy of his Lead Auditor Certification l for historical file records. RG Target Comoletion Date: 5/15/97 1

2) Probams with Certificate of Compliance: ML a) Ameron Order # 570680 for Wolf Creek needs to have Certs generated. )

Target Comoletion Date: 3/31/97 b) C1eck other Nuclear Record hies for completeness of paper work. j Taract Comoletion Date: 5/15/97 l

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3) Calibration System needs to be brought up to date. Data sheets need to reflect As Found, As Adjusted, Date Checked and By Whom.

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Target Comoletion Date: 4/30/97 l

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RON NO: 01/97-005 RESPONSIBLE MANAGER (S): M. Lamb

1) Revise Work Instruction Wl005 for a) Periodic intemal audits b) Periodic Management reviews Target Completion Date: 5/15/97

2) Management Reviews need to be documented better and evidence

. needs to be filed so that it is more accessible. Establish practice.

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Taraet Completion Date: 7/31/97 i

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RON NO: 01/97-006 RESPONSIBLE MANAGER (S): M. Lamb

1) Implement the following Work Instructions:

a) W1094 Customer Interface i

Target Comoletion Date: 6/15/97 1 I

l b) W1099 Contract Review Taroet Comoletion Date: 6/15/97 i l c) Wl158 ? Nuclear Orders Target Comotetion Date: 7/15/97 d) Wl098 Auditor Qualifications Target Comoletion Date: 7/15/97 1

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RON NO: 01/97-007 RESPONSIBLE MANAGER (S): G. Smith, M. Lamb

1) Review W1099 and Wl094 for accuracy, completeness and current application. GS l Target Comoletion Date: 5/15/97 I

2) Develop method / procedure where all of the requirements of new, Nuclear orders are reviewed prior to acceptance of the initial PO. GS Target Comoletion Date: 5/15/97

3) Develop method / procedure where "all" Nuclear PO requirements are related to all of the personnel involved in the entire Nuclear production process from Raw Material procurement through Product Shipment. GS Target Comoletion Date: 6/30/97 l

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1 RON NO: 01/97-008 RESPONSIBLE MANAGER (S): M. Lamb, S. McKown  ;

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1) Revise W1041 to reflect current practice. ML 1

Target Completion Date

6/15/97

2) Implement procedure where our Quality System requirements are listed as part of the Ameron PO for calibration services. SM l l

l Target Comoletion Date: 4/30/97 l l

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Page 12 RON NO: 01/97-009 RESPONSIBLE MANAGER (S): M. Lamb

1) Revise Wl004 to reflect current practice.

a) Indicate that Ameron will conduct audits of suppliers and / or do incoming calibration check to verify calibration services' I work.

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b) Establish an Audit Schedule for Calibration Services.

Taraet Comoletion Date: 6/15/97

2) Set up master file for all calibration services used.

Taraet Comoletion Date: 5/15/97 l

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l l RON NO: 01/97-010 RESPONSIBLE MANAGER (S): R. Gasmena

1) Establish method / procedure to inform Raw Material Receiving l personnel of the individual raw material receiving requirements.

Ig.rget Comoletion Date: 9/30/97

2) Review Raw Material Procurement Sheet requirements for critical /

non-critical Raw Materials for Nuclear products.

Target Completion Date.; 9/30/97

3) Set up method / procedure to require identification of QC personnel conducting individual tests and M & TE used on individual tests during QC Raw material Testing. These records need to allow traceability to training records and M & TE calibration records for Nuclear " critical" raw materials.

Taraet Comoletion Date: 8/31/97

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RON NO: 01/97-011 RESPONSIBLE MANAGER (S): M. Lamb l

1) Calibrate M & TE that is due for calibration / remove from service.

Target Completion Date: 4/30/97 l

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2) Document Calibration on SN0002 Scale and SNC11 Wt/ gal cup.

Taraet Completion Date: 2/19/97 Completed 1

3) Deiine calibration procedures which are needed. Write and implement these Work Instructions as required.

Target Comoietion Date: 10/15/97 1

1 l 4) Write and implement Work Instructions for Receiving personnel i indicating that nev', in-coming M & TE and retuming M & TE which has been sent out for calibration must first be routed through QA for verification and entry into the calibration system and then forwarded to the department that has purchased the equipment.

Inget Completion Date: 10/15/97 l

doc. nupici wpd, M Lamb,2/27/97. Version 3.

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