ML20147C474
| ML20147C474 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/1978 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Schwab G DRAVO CORP. |
| Shared Package | |
| ML20147C480 | List: |
| References | |
| REF-QA-99900017 NUDOCS 7810130022 | |
| Download: ML20147C474 (1) | |
Text
4 g. gA #tooq'o UNITED STATES g
NUCLEAR REGULATORY COMMISSION
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REGION IV o
611 RYAN PLAZA DRIVE, SUITE 1000 ARLINGTON, TEXAS 76011 2 6 SEP 1978 THIS DOCUMENT CONTAlHS Docket No. 99900017/78-01 P00R QUAL.lTY PAGES r
Dravo Corporation Pipe Fabrication Division Attn:
Mr. G. Schwab Vice. Presi dent 1115 Gilman Street Marietta, OH 45750 Gentlemen:
Thank you for your letters, dated June 30, July 14, August 7, and September 14, 1978, in response to our letters dated May 22, and September 1,1978.
We have no further questions at this time and will review your corrective action during a future inspection.
Sincerely, i
l Uldis Potapovs, hief Vendor Inspection Branch 3
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GUSTAV $CHWAS vice Pres dent.
I c+a...i u.aner September 14, 1978 P,oe FaboceSon Dws.cn United States Nuclear Regulatory Commission Region IV f;
611 Ryan Plaza Drive, Suite 1000 g.
Arlington, Texas 76011-Attention:
Mr. Karl V. Seyfrit, Director I
Subject:
NRC Audit Findings Docket No. 99900017/78-01 Centlemen:
Thank you for your letter of September 1,1978. We are pleased that you find our responses and corrective action for the various findings in your original audit are now satisfactory with the exception of one, namely, Item D.
f Regarding Item D covering monitoring of manual welding, we have submitted-our inquiry to the ASME Code Committee as we had proposed to obtain some guidance as to the acceptabic frequency for monitoring welders. Enclosed is a copy of our letter of inquiry dated August 28, 1978. However, we do not expect an answer for several months.
In the meantime, we have ordered 20 meter boxes which we will attach to 20 manual welding machines. We propose to monitor weldcrs, using these machines on essentially a daily basis to establish the fact that they are velding within the amperage of the applicabic procedure used. After a one-month monitoring period, which we believe will demonstrate that our welders are welding within specified parameters, we intend to discontinue this intensive monitoring program and revert to our present program of monthly surveillance audits. Meter boxes installed will be lef t on the f
machines for use for surveillance by foremen and inspection personnel.
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If during this intensive monitoring period any problem areas develop where welders are not welding within specified electrical parameters, suitable corrective action will be implemented.
Meter boxes are not off the shelf items and it will be the end of October before they will be available 1n our shops.
Considering a one-month period for monitoring, we should know by the. end of November how our welders are doing.
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Mr. Karl V. Seyf rit 1
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In the =cantine, we vill continue to conitor 20 to 30 welders per conth -
tt half of which vill be =anual - until we can start the program as outlined above.
- e hope this reets with your approval.
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Tha American Society of Mechanical Engineers United Engineering Center /345 E. 47th St.
i New York, NY 10017 1
Attention:
W. B. Hoyt
Subject:
. Control of Manual Welding Gentlemen:
(
Below is an inquiry with some background information.
Will you please refer the matter to the proper committee for an answer.
INQUIRY What " measures" does the Code intend be established to assure compliance with NCA-4134.9, Summer 1977 (NA4451, 1974), for' manual welding processes?
Must every weld, welder / operator and weld machine be checked or monitored?
If so, what would be an acceptable frequency?
If not, would a random audit with provision for increasing ~the frequency in case of noted deficiencies be acceptable?
DISCUSSION Manual and semi-automatic welding may be performed with a constant current, drooping volt-amp curve, power source.
The drooping characteristic of the volt-amp curve prohibits use of absolute voltage and amperage cont settings.
Welding voltage and amperage is determined by Ohms law relationsk
/1th are length basically determining resistance.
Section 1X requires tha amperage and voltage be specified on the Weld Procedure Specification as a non-essential l
variable.
NCA-4134.9 states in part, " Measures shall be established to a'ssure that processes, such as welding... are accomplished... using qualified procedures." This, then, raises the question of the inquiry.
It is noteworthy that ASMI, in response to an earlier inquirey, stated that calibrated volt and amp meters are not required for constant current welding machines.
4 Dravo is presently performing random audits on a monthly basis. We audit a minimum of twelve (12) welds a month.
We do not attempt to include every wolder/ operator in the audit on a prescribed frequency.
This program has been judged unacceptable by a team (not ASME) auditing our plant.
Very truly yours, R/G 1
W. A. Molvie Quality Assurance Manager mar m - -
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NUCLEAR REGULATORY COMibilSSIOM UNITED STATES c9 h> 7' n
REGloN IV 4
611 RYAN PLAZA DRIVE SUITE 1000 s
Thank you for your letters of June 30, July 14 and August 7,1978, responding to our letter and enclosure dated May 22,.1978. We have evaluated the information which you have provided, including your general commitment for increased emphasis in the implementation of your Quality Assurance program through additional, personnel, manage-ment reassignments and manual / procedure revisions.
With the exception of item D we find your responses to the specific deviations referenced in our May 22 letter satisfactory pending verification of the comitted corrective actions during a subsequent inspection.
After reviewing the additional information on item N, which was submitted with your August 7,1978 letter, we no longer consider this a deviation and our records will reflect this fact.
With respect to item D, however, we do not consider your random sampling approach adequate to verify that all welders are performing within the required parameters of the applicable procedures. We interpret Appendix B to 10 CFR 50 and the ASME Code as requiring a more systematic and comprehensive method, which would include periodic monitoring of all weldors and equipment used in the fabrication of safety related nuclear components.
Please submit additional information relative to item D, above, des-cribing a proposed method of conformance within twenty (20) days of the date of this letter so that we can complete our evaluation. Your response should include any information related-to the ASME Code inquiry which you reference in your June 30 letter.
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Dravo Corporation 2
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Regarding your offer to meet with us for additional discussion of the
. previous findings, we propose to conduct another inspection of your facilities'before determining whether such meeting would be necessary.
Thank you for your cooperation.
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Sincerely,.
$I Karl V. Seyfr' t Director i
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August 7, 1978 United States Nuclear Regulatory Commission East West Towers Building 4350 East / West Highway Bethesda, Maryland 20014 Attention:
Mr. Norman C. Moseley, Director -
Division of Reactor Construction Inspection Office of Inspection and Enforcement
Subject:
NRC Audit Findings Docket Number 99900017/78-01 Dear Mr. Moseley Our letter of June 30, 1978, April 10-13, 1978, audit.
responded to findings made during your With reference to item "N" of your findings and to further explain our response that we were proceeding in accordance with contractural instructions from our customer, we are attaching a copy of our Ictter dated June 23, to Bechtel Power Corporation and their reply dated July 21, 1978.
You will note that Bechtel agreed that we are following their instruc-tions.
Our decision to take no corrective action in response to your finding is therefore, in our opinion, proper.
In addition to advising you of these further developments in this-matter, the purpose of this letter is to strongly recommend that you eliminate this finding from further consideration and from publi-cation in the " White Book".
We hope you agree.
Very truly yours, DRAVO CORPORATION Pipe Fabrication Division k
W. A. Molvie Quality Assurance Manager WAM/mrb Enclosures Ptpr rAsRICATION OfWlSION @R AV@ @DR
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July 14, 1978 k
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t Mr. Norman C. Moseley, Director j.'
Office of Inspection and Enforcement-Division of Reactor Construction Inspection
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East West Towers Building 4350 East / West liighway e
Bethesda, Maryland.20014 h
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Dear Mr. Moseley:
h Supplementing my letter of June 30, 1978 on above subject, I am I.
pleased to announce that we have changed our organizational y
structure and have assigned Mr. W. A. Molvie, formerly our Chief L
Engineer, to the position of Manager - Quality Assuranc = and.
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Technical Services reporting directly to the General Manager.
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Mr. Molvie has been relieved of his responsibility for Production Engineering and will now devote his full-time to Quality Assurance
, s-p and related matters.
This is an additional step we are taking to reinforce our Quality Assurance Program.
Since/ rely,
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./ Vice President and General Manager k
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U. Potapove t
D. M. Hunnicut i
O R A V O C o R P U.R A T I O N -~ 1115 G I L M A N S T R E E T M ARIE T T A. o H 45750 614 373 7541
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CORPORATl ON June 30, 1978 K...:q..
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United States Nuclear Regulatory.Commissica e], ' "]
East West Towers Building 4350 East / West Highway j QF3 Bethesda, Maryland 20014
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Mr. iiorman C. Moseley,. Director Division of Reactor Construction Inspection Office of Inspection and Enforcement.
Subject:
NRCAuditFinkings......-
Docket Number.99900017/78-01.
Dear Mr. Moseley This letter is in response t[your letter on the subject Docket dated May 22, 1978 and received by.us.May.26,.1978. We have contacted your Mr. Potapovs and requested and. received a one-week. extension on the time for our reply to give us. time. to further review our position with our Authorized helear Inspection Agency..
Regarding the specific findings.of your April 10-13, 1978. audit, we are attaching our response, fueluding steps taken to correct' specific de-ficiencies, action to be taken.to preclude, recurrence and dates on which these will be completed.,
Your letter concludes that your. findings. indicate.our program described in our Quality Assurance Manual is. inadequately inplemented. Actually, in reviewing the findings on an.overall basis, we. feel that in general our program was being implemented. in.accordance.with our personnel's understanding and interpretation of..same._ However, our Manual as written was subject to differing interpretations. In many instances, the cause of the findings was resolved.by.. changing.the wording in.our Manual.
We have concluded that in many. cases our Manual' has gone into too much e
- %i detail in specific areas. For.the.past nine months we have had t.n ax-tensive effort to supplement. the.danual with detailed written procedures..
During the balance of this year.we.will.be completely. reviewing and re-T:
vising our Manual and hopefully simplitying it so it will not be subject to varying interpretations.
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-continued-.
l PIPt F A SRIC ATION DIVISION
'l81 5' GIL M AN STREET M A nt B E T T A, OHIO 45750 614 373 7S41 l
DRAV O CORPORATION SHELv N o.
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United States Nuclear Rsguistory.Comiscion Ju'ns 30, 1978 1
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Your most recent audit included.six.. findings where.we.did not meet previous coenitments for the tine when. proposed, corrective. action.would. be. finalized with written procedures. In most. cases,. the corrective action had been imple-mented but the written procedures. net. issued on. time.. ~The severity of. this type of problem had not developed.during. previous audits,.We.had an unusual
'W situation in late 1977 and early.1978.whereby.our Quality. Assurance personnel I
were extremely overloaded in. resolving problems,. developing new written.
. l procedures, etc., which caused us to. mise.these. commitments. We reviewed 3
with you at our May 8 meeting.some of.the general problem areas on which f
we were working, including a complete, review and. revision.of our veld procedures and a review and substantial change.in.our interface, relationship with our Authorized nuclear Inspector...
Topreventthissituationfr$. recurring...weare.addingan.additionalquali-fied Quality Assurance Enginear who.will.be.available August 1,1978. In addition, we are instituting.a. punch list.of actions. committed in response to Quality Assurance audits which.will_be. monitored.by Management to assure.
that commitments are proceased.and. completed. on. time.. If.for any reason it is not possible to meet commitments as. originally made,.we will contact the organization involved in. advance and.a.new commitment date established..
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With the rapid expansion of our.. Quality. Assurance. Department.in the past.two years, we had become severely. handicapped.because.of' congested. office fa-cilities. We have recently completed.new.and expanded. office.faM* *~les.for this department and moved into.the.new. space. June 26,..1978... The + <ew offices i
also incorporate an office for.our. Authorized. Nuclear Inspector h ich.will more readily permit close liaison with.him and give him more. ready access to our records.
...., =...
In reviewing your most recent findings,.we are.particularly concerned with the fact that six of these represent honest. differences.of opinion between Dravo and the NRC Auditors as to whether the. findings.are.in. fact deficiencies..
These specific findings are A,.D, I..K,.M,.and.Q.,.Two.of these findings are repeat findings, namely K and.M.r.In some. cases.we..have takan. corrective action to clarify or revise our.. Manual.or procedures.but in some we have.
indicated no specific corrective. action...We.do not mean. to.be unresponsive.
If it would seem advisable to.get together to, resolve.these differences of opinion, we would welcome the. opportunity.at.your. convenience..
Regarding the comitment of ur. Management. tr.. maintain = a. fully imple mented,
effective Quality Assurance Program, you.can be. assured that there is such I
commitment. As we discussed.st.our. meeting.May. 8,.it.is.most disturbing to l
ee personally that apparently.some of.your audit personnel.do not agree that-I we have been exerting subotantial. effort.and achieving. significant progress 1
during the past year to resolve.out. problems.and.reffne.our. program. Hope-
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fully, the results of their next. visit.will. prove. convincing.
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0RAVo C O M *P Q R A T / o N '
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United Statto liuclser Regulatory Comnission _,
June 30, 1978 j
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After you and your peopic have had an opportunity to review the details of
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our responses to your most recent. findings, we would be pleased to get to-j gether to discuss any open areas..
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Sincerely, DRAVOf'CORPO
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UNITED STATES -
f NUCLEAR HEGULATORY COMMISSION y.
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Docket Number 99900017/78-01 i
Dravo Corporation Pipe Fabrication Division Attn: Mr. G. Schwab Vice President 1115 Gilman Street Marietta, Ohio 45750 Gentlemen:
This refers to the Quality Assurance Program inspection conducted by Mr. I. Barnes of the NRC Region IV office on April 10-13, 1978, of your 1'
facility at Marietta, Ohio, associated with the fabrication of nuclear piping assemblies and to the discussions of our findings with you and members of your staff at the conclusion of the inspection, and at a subsequent meeting at our offices in Bethesda, Maryland, on May 8,1978.
This inspection was made to confirm that, in the areas inspected, your QA Program is being effectively implemented.
The inspection effort is not designed to assure that unique quality requirements imposed by a customer are being implemented; nor to assure that a specific product, component or service provided by you to your customers, is of acceptable quality. As you know, the NRC requires each of its licensees to assume full responsibility for the quality of specific products, components or services procured from others.
You should therefore not conclude that the NRC's inspection exempts you from inspections by a NRC licensee or his agents nor from taking effective corrective action in response to their findings.
Areas examined and our findings are discussed in the enclosed report.
Within these areas, the inspection conaisted of an e.xamination of procedures and representative records, interviews with personnel, and observations by the inspector.
Dravo Corporation 2 2 Wa During the inspection it was found that the implementation of your QA Program failed to meet certain NRC requirements.
The specific findings and references to the pertinent requirements are identified in the enclosures to this letter.
In accordance with Section 2.790 of the Commission's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter with enclosure and your reply, together with the enclosed inspection report will be placed in the Commission's Public Document Room.
If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within thirty (30) days to this office to withhold such information from public disclosure.
Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
As we discussed in the May 8 meeting, during the last two years in which NRC has been inspecting the Dravo Corporation Pipe Fabrication Division, a large number of deviations have been identified in a broad scope of quality program areas.
These results indicate to us that the program described in your Quality Assurance Manual has been inadequately implemented.
Further, we have found numerous instances where your company has failed to meet corrective action commitments made in re-sponse to prior NRC inspection findings.
Our inspection results demon-strate a significant failure by management to devote sufficient at-tention to the implementation of an effective quality program.
It is our view that prompt, vigorous corrective action is necessary.
Please provide us within thirty days of your receipt of this letter a written statement containing:
(1) a description of steps that have been or will be taken to correct specific identified deficiencies; (2) a description of management measures which have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures will be completed.
Our inspection covered only limited program-matic areas, but deficiencies identified in those areas are indicative of larger program problems.
Therefore, in your response, please also describe actions you plan to take to correct the broad deficiencies in implementation
i W 22ma of your quality program.
Dates should be provided on which individual steps in your overall upgrading action will be completed. We plan to reinspect your facilities in the near future and exp2ct to be able to make positive findings.
Sincerely, 7
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,// Norman C. Moseley Director Division of Reactor Construction Inspection Office of Inspection and Enforcement
Enclosures:
1.
Notice of Deviation 2.
Inspection Report No. 99900017/78-01 I
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j Dravo Corporation Docket No.
99900017/78-01
' NOTICE 0F DEVIATION Based on the results of an NRC inspection conducted on April 10-13, 1978, it appears that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
A. Dravo corrective action response letter dated November 23,.1977, states in part with' respect toL item 1.D.3.a. (1) of IE Report' No. 77-01,
"... The welding. foremen have been instructed and trained to include all variables over which a welder can exercise control on the Weld.
Joint Data card before giving to the welders...."
a Contrary to the above, the inspector observed that all. variables over which a welder can exercise control were not being included by the welding foremen on Weld Joint. Data cards supplied to the welders, as illustrated by the following examples:
1.
The Weld Joint Data card applicable to the gas tungsten arc welding operation on Weld B, Job No. 3002, Sketch 427, did not specify the required maximum interpass temperature. the required purge gas flow rate, polarity to be used or reference the method of initial and interpass cleaning to be'used.
2.
The Weld Joint Data card applicable to the gas tungsten arc welding
.i operation on Weld E, Job No. 3000, Sketch 218, referenced two (2) unidentified shielding gas flow rates of 25-50. cfh and 0-10 cfh.
Examination of the applicable welding procedure specification, 1-1-W 6104-L5, Revision 6, showed three (3) stipulated argon flow rates, i.e. for the torch, for the hot wire feed device and for the inside purge. -It was further noted that the flowmeter for the hot wire device had been removed from the equipment.
B.
A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item I.C.3.a.(1) of IE Report No. 77-02,
"... Dravo will prepare a General Welding Specification on or before February 28, 1978, incorporating shop standards for all welding processes to be used for. tacking...."
i Contrary to the above, the inspector was advised on April 12, 1978, i
that the general welding specification had not been finalized.
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C.
A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item I.C.3.a.(3) of IE Report No. 77-02,
"... This item will be included in our audit check list of production activities by 3/31/78...."
Contrary to the above, the inspector was advised on April 12, 1978, that the item had not yet been included in an audit checklist of production activities.
D.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall
^
be established to assure that special processes, including welding,
... are controlled and accomplished... using o,ualified procedures Paragraph NA-4451 in the ASME Section III Code (1974 Edition) states in part, "... Measures shall be established to assure that processes including welding... are accomplished... using qualified proce-dures."
Contrary to the above, measures were not established with respect to certain welding power sources e.g. Hobart S/N 66773, which would assure conformance of amperage output with the requirements of applicable welding procedure specifications, in that:
1.
No method or means of correlating dial. settings with amperage output was at the work station.
2.
The QA Manual does not specifically require welding foremen to perform any checks of electrical parameters used by welders relative to procedure requirements, nor is equipment assigned to them to perform such functions.
3.
Procedure GWS-6, Revision 1, which defines requirements for inde-pendent surveys of production welding operations by Welding Engineering, utilizes a random selection basis for operations witnessed and has no provisions to assure that all qualified welders are progressively surveyed to verify compliance to proce-dure requirements at a specified frequency.
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4.
Review of Welding Engineering survey records dating from June 1973, i
for a sample of twelve (12) welders taken from a qualified welders I
list, showed two (2) shielded metal arc welders who had never been i
surveyed.
The inspector also observed two (2) additional welders, j
who were listed as qualified for all Dravo active processes, that I
had never been surveyed for any process.
The inspector was informed that the latter two were actually welding foremen, for whom until recently it had been the Dravo practice to maintain welding qualifications.
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. E.
A Dravo corrective action response letter dated November 23,~1977, states in part, with respect to item II.C.3.a.(1) of-Report No. 77-02, "A manual revision will be made and issued prior to March 31, 1978, which will clarify this commitment so as to allow recording of the information to occur anytime prior to final inspection."
Contrary to the above, a manual revision to clarify this commitment was not issued prior to March 31, 1978.
F.
A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item II.C.3.a.(4) of IE Report No. 77-02,
"... our QA Manual will be revised prior to March 31, 1978, to include a requirement for the recording of_the procedures and revision letters on the specific back-up shop documents...."
Contrary to the above, the QA Manual was not revised prior to March 31, 1978, and the applicable revision to correct this deviation had not been issued as of the date of this inspection.
G.
A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item II.C.3.a.(5) of IE Report No. 77-02,
"... A new procedure will be written to specifically delineate this commitment.
This procedure ES-DOC-3 will be written and implemented
- i prior to 1/1/78...."
Contrary to the above, a new procedure ES-DOC-3 was not written and implemented prior to 1/1/78 but was written on 4/10/78, over three (3) months later.
H.
10 CFR 50, Appendix B, Criterion IX, states in part, " Measures shall be established to assure that special-processes, including welding, heat treating, and nondestructive testing are controlled.... in accordance with applicable codes, standards, specifications, criteria and other special requirements."
Section V, Article 6, of the ASME Code, paragraph T-630, states in part, "When using penetrant examination methods for nickel base alloys the penetrant materials shall be analyzed for sulfur content....
The total sulfur content shall not exceed 1% by weight....
When examining austenitic stainless steels....
The total halogen content of the residue shall not exceed 1% by weight."
l Contrary to the above, it could not be verified that the total sulfur and halogen content of the residue did not exceed 1% by weight for the penetrant materials used to examine nickel base alloys and austenitic stainless steels, in that, the_ containers used to dispense bulk penetrant materials contained a residue of an unknown substance.
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10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances Paragraphs NB, NC and ND-5521 of ASME Section III Code (1977 Edition) state in part, " Certification of Level III nondestructive exami-j nation personnel by examination technical competency is required.
The procedure used for examination shall be described in the written practice which is required by SNT-TC-1A-1975..."
The above requirement was mandatory as of October 1, 1977, with the expiration of Code Case N-138 (1769-1).
Contrary to the. above, the procedure used for examination of Level III nondestructive examination personnel is not described in the Dravo written practice, ESM-QA-2, which is required by SNT-TC-1 A-1975.
J.
A Dravo letter of corrective action dated November 23, 1977, states in part with respect to item III.D 3.a. of IE Report No. 77-02, "...
Furthermore, a procedure has been written and imposed for the control of vendor audits...."
Contrary to the above, although the specified procedure was found to be in a rough draft stage, the provisions of the draft were not being imposed.
K.
Criterion XVIII of Appendix B to 10 CFR 50 states in part, "A com-prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
The audits shal1 be performed in accordance with the written procedures or check lists Section 17 of the Quality Assurance manual, paragraph 3.5, states,
" Audits performed in accordance with written checklists shall be made periodically during the year." Also, Section 17 of the Quality Assurance Manual, paragraph 3.5.1, states, "Each such checklist shall be completed at least once a year."
Contrary to the above, certain audits had not been performed once a year, in that the corresponding written checkl'ists had not been com-pleted once a year.
Examples: Weld Engineering and Production Welding, Purchasing department, and Inspection department.
A similar deviation was previously identified and reported in Report No. 77-01 and in Report No. 77-02.
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L.
Criterion XVIII of Appendix B to 10 CFR 50 states in part, "...
Audit results shall be documented and reviewed by management having responsibility in the arca audited...."
Section 17 of the Quality Assurance Manual, paragraph 3.3, states, "Results of the audits shall be distributed to the General Manager, Chief Engineer / Quality Assurance Manager, Quality Assurance Supervisor, Manager of 0perations, Chief Inspector, Authorized Inspector, and other appropriate management personne'. naving responsibility in the areas audited."
Contrary to the above, a sample revealed that results were not distributed to the Chief Inspector in one instance, and to the Authorized Inspector in another instance.
M.
Criterion III of Appendix B to 10 CFR 50 states in part, "... The verifying or checking process shall be performed by individuals or groups other than those who performed the original design...."
Section 3 of the Quality Assurance Manual, paragraph 4.2, states, "To insure accuracy the sketches shall be checked, initialed, and dated by one other individual in Engineering prior to issuance."
Contrary to the above, a sample revealed that sketches were not checked, initialed, or dated by one other individual in Engineering.
Examples:
E-2803-143, E-2803-159, E-2803-155, E-2803-143, E-2803-15, E-2803-4, E-2803-5, E-2803-76, E-2803-546, and E-2803-548.
A similar deviation was previously identified and reported in Report No. 77-02.
N.
Section 3 of the Quality Assurance Manual, Revision 3, paragraph 4.6, states, " Sketches are submitted for customer approval when required by contract."
Contract specification 10855-P-201(Q), paragraph 9.3.1, states in part, "The following drawings shall be submitted and approved prior to start of fabrication:
(a) Spool detail sheets for class 1 and class 2 piping; class 3 piping that is seisgic category 1; and class 3 piping with a design temperature exceeding 21 F or a pressure exceeding 150 psig...." Also, the same specification page 12 of 17 under the paragraph " RELEASES" states in part, "... Seller is released to commence fabrication upon receipt of Code I status spool sketches."
i
?
Contrary -to the above, a sample revealed that certain spool details e
sheets. for class 2 piping had been released for fabrication, even though prior. approval had not been.obtained.
Examples:
E-3035-G, E-3035-22, E-3035-20, E-3035-28, E-3035-32, E-3035-34, E-3035-37, E-3035-40, E-3035-41, E-3035-46,- and E-3035-54.
A similar deviation-was previously identified and reported in'-
I 4
Report No. 77-02.
~
0.
Section14oftheQualityAssurance; Manual, paragraph 3.2.7, states, t
"The ANI shall be given the opportunity to review the disposition on all Code items and nonconformances and to establish mandatory hold.
points."
Also, paragraph 3.2.7.1~ of the same section states, " Completion of such review shall be indicated by his initialing and dating the NCR prior to returning:it to Quality Assurance."
Contrary to,the above, certain nonconformance reports (NCR) had not been presented to the ANI as required.
Examples: NCR E-3035-QA 33, E-3035-QA 23, E-3035-QA 17, J-2603-QA 61, E-2803-QA 53, E-2803-QA 49, and E-3000-QA-15.
A similar deviation was previously identified and reported in Report No. 77-01.
P.
Criterion XV of Appendix B to 10 CFR 50 states in part, " Measures shall be established.to control materials, parts, or components which.do not conform to requirements in order to prevent their inadvertent use or installation...."
Section 14 of the Quality Assurance Manual, paragraph 3.1, states in I
part, "Nonconformances are defined as ' items that, because of deficiency 1
in characteristic, documentation or procedure render the quality of the item unacceptable or indeterminate'....
Section 7 of the Quality Assurance Manual, paragraph 11.5, states,
" Rejected material shall be physically separated, when practical, from acceptable material." Also, paragraph 11.5.1 of the same section states in part, "It shall be marked by both a red tag and trouble tag...."
Contrary to the above, the' following materials with discrepant CMTR's were not red tagged or trouble tagged.
Examples:
E-3036 CMTR#43, E-3035 CMTR#139. E-3035 CMTR#142, and ' E-3035 CMTR#275.
A similar deviation was previously identified and reported in Report No. 77-02.
s m
e Q.
Criterion XII of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."
Section NCA 4134.12 of the ASME Code states in part, "... Calibration shall be against measurement standards which have known relationship to national standards...."
Contrary to the above, certain masters are not traceable to the national standards, in that they have been removed from the calibration control program.
Examples:
Gage Blocks, Dead weight tester weights, Dead weight tester, and Radius Gages.
l VEND 0R INSPECTION REPORT
)
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
09900017/78-01 Program No.
44020 Company:
Dravo Corporation Pipe Fabrication Division 1115 Gilman Street Marietta, Ohio 45750 Inspection Conducted: April 10-13,1978
?/)
v>ud Inspecto)W I. Barnes, Contractor Inspector, Vendor 5 8 /70 s:
/ Dat6
)
Inspection Branch I224'}l~ 6 at
)e'H.W.Roberds,ContractorInspector, Vendor A//8l78 7t
/ Dat6
/
Inspection Branch l Yw>&ea$
Y/8l79
[ P. I. Verrios, Contractor Inspector, Vendor
' Date'
/
Inspection Branch Approved by:
f/[
mw$a8 h
8 /78 s
D. M. Hu'nnicutt, Acting Chief, Vendor
/Date' Inspection Branch Summary Inspection on April 10-13, 1978 (99900017/78-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including control of praduction welding; elevated temperature heat treatment; nondestructive e'. amination (dye penetrant);
material control; internal audits; procurement contr'.,1 (vendor audits); design and document control; nonconforming materials, parts or components; equipment calibration and action on previous inspection findings.
The inspection involved seventy-five (75) inspector-hours on site by three (3) NRC inspectors.
J
, Results:
In the ten (10) areas inspected, no apparent deviations or unresolved items were identified in two (2) areas; the following were identified in the remaining areas.
Deviations: Action on Previous Inspection Findings - Completion of Weld Joint Data cards by welding foremen not consistent with corrective action commitments (Enclosure, Item A.); failure to prepare a General Welding Specification relative to tack welding in accordance with corrective action commitments (Enclosure, Item B.); failure to include a certain NRC finding in an audit checklist of production activities in accordance tith corrective action commitments (Enclosure, Item C.); failure to make a QA Manual revision in accordance with corrective action commitments (Enclosure, Item E.); failure to make a QA Manual revision in accordance with corrective action commitments (Enclosure, Item F.); failure to write and implement a with corrective action commitments (Enclosure, Item G.) procedure in accordance
- failure to impose the specified procedure relative to vendor audits in accordance with corrective action commitments (Enclosure, Item J.).
Control of Production Welding -
Control of certain welding power sources with regards amperage output not consistent with the requirements of Criterion IX of 10 CFR 50, Appendix B, and paragraph NA-4451 of the ASME Code (Enclosure, Item D.).
Nondestructive Examination (Dye Penetrant) - Control of penetrant materials not consistent with Criterion IX of 10 CFR 50, Appendix B, and Article 6 of the ASME Code Section V (Enclosure, Item H.); qualification of Level III NDE personnel not consistent with Criterion V of 10 CFR 50, Appendix B, and paragraphs NB/NC and ND-5521 in the ASME Code (Enclosure, Item I.).
Internal Audits -
Contrary to Criterion XVIII of 10 CFR 50, Appendix B, certain internal audits had not been performed (Enclosure, Item K.); contrary to Criterion XVIII of 10 CFR 50, Appendix B, results of internal audits were not distributed to Chief Inspector and to the Authorized Inspector (Enclosure, Item L.).
Design Control - Contrary to Criterion III of 10 CFR 50, Appendix B, sketches were not checked initialed, or dated by one other individual in Engineering (Enclosure Item M.); contrary to Criterion III of 10 CFR 50, Appendix B, spool detail sheets for class 2 piping had been released for fabrication without prior approval as required by Customer Specification (Enclosure, Item N.).
Nonconformances and Corrective Action - Contrary to the require-ments in Section 14 of the QA Manual, certain nonconformance reports had not been presented to the Authorized Nuclear Inspector (Enclosure, Item 0.);
contrary to Criterion XV of 10 CFft 50, Appendix B, certain materials with discrepant CMTR's were not red tagged or trouble tagged (Enclosure, Item P.).
Equipment calibration - contrary to Criterion XII of 10 CFR 50, Appendix B, certain masters are not trace W e to the national standards, in that they have been removed from the cz
> ration program (Enclosure, Item Q. ).
Unresolved Items:
External Audits (Vendor audits) - Based on the subjective wording of the Dravo Quality Assurance Manual, the area of vendor audits is not aditable.
(DetailsSection III, paragraph D.3.b. )
1 DETAILS SECTION I (Prepared'by I. Barnes) f A.
Persons Contacted
- G. Schwab, Vice President and. General Manager
- W. A. Molvie, QA Manager and Chief Engineer.
- E. R..Dysent, Operations Manager
- R. L. Anderson, QA Supervisor
- R. L. Davis, Welding Engineer L. Dean, Project' Supervisor
- D Gilchrist,'QA Engineer l
- J. Llewellyn, Project Engineer R. L. Miller, QA Engineer
- J. Moore, Chief Inspector
- P. P. Norris, Chief Metallurgist
- L. W. Stiles,. Project Supervisor
- W. Smith, Authorized Nuclear Inspector, Hartford Steam Boiler Inspection and Insurance Company t
- T. J. Whitacre, QA Engineer;
- Attended exit meeting.
t B.-
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 77-01, DetailsSection I,
[
paragraph D.3.a.(1)):
Performance of shielded metal arc welding.
with 1/8 in. E7018 electrodes at-amperage values above the range specified by the applicable welding procedure specification.
t The inspector verified that the committed Weld. Engineering review of welding procedures had been performed, monthly audits of i
welding operations had been implemented and that the foremen had received instructions relative to this item.
The inspector ascertained, however, that current use of Weld Joint Data cards was not in accordance with committed corrective actions.
(SeeEnclosure,ItemA).
2.
(Closed) Deviations (Report No. 77-01, DetailsSection I, paragraphs D.3.a.' (3), (4) and (5)).
'(
j
r
, The' inspector verified that the committed instructions had been given and that Standard Procedure, SP-3 had been appropriately revised with respect to performance of base material weld repairs and distributed.
3.
(Closed) Deviation (Report No. 77-02, DetailsSection I, para-graph C.3.a(1)):
Performance of tack we' ding without a color coded process form having been issued to or in the possession of the selected operator.
The inspector verified by review of current production welding records that committed corrective action had been implemented with respect to control of tack welding by use of Weld Joint Data cards.
It was also established that monthly audits by Weld Engineering now included tack welding.
The inspector ascertained, however, that all corrective actions had not been completed as committed. (See Enclosure, Item B.).
4.
(Closed) Deviation (Report No. 77-02, DetailsSection I, paragraph C.3.a.(2)):
Use of Weld Joint Data cards observed to be at variance with the requirements of applicable qualified welding procedures.
The inspector verified that use of preprinted Weld Joint Data cards had been discontinued and that parameters were now being I
recorded on blank cards from the specific welding procedure specification being used.
5.
(Closed) Deviation (Report No. 77-02, DetailsSection I, paragraph C.3.a. (3)):
Absence of evidence on Quality Control and Assurance Data Sheet that required fit-up inspection had been performed, although welding was observed by the inspector being completed.
The inspector verified that the committed training had been performed.
The inspector ascertained, however, that the corrective action to preclude recurrence had not been implemented as committed (See Enclosure, Item C.)
9
, 6.
(Closed) Devaition (Report No. 77-02, DetailsSection I, para-graph C 3.a.(5)): Absence of records to allow verification, that specific provisions of the ASME Code with respect to preheat and interpass temperature and cooling rate from the post-weld heat treatment temperature range, were complied with in qualification of certain welding materials for ASME Section III application.
The inspector verified that the committed corrective actions had been implemented with respect to review and upgrading of welding materials and that procedure, GWS-4, Revision 0, had been transmitted to the Quality Assurance Department.
7.
(Closed) Unresolved Item (Report No. 77-02, DetailsSection I, paragraph I.C.3.b. ): Approval of WPS 1-1-A1502-P7, Revision 1, for Job No. E-2803 with a supporting procedure qualification record showing one tensile strength value of 61,550 p.s.i. with failure in the weld.
The inspector verified that the Dravo response was correct with respect to ASME Section III and Section IX requirements.
C.
Control of Production Welding 1.
Objective The object'ives of this area of the inspection were to verify that production welding was controlled in accordance with applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 9 Revision 3, " Control of Special Processes."
b.
Review of fabrication requirements in customer specifica-tions 9763-006-248-1, Revision 2; and 10466-M-201 A, Revision 9.
Observation of two (2) hot wire gas tungsten arc and one c.
shielded metal arc production welding operations.
. d.
Review of Weld Joint Data cards supplied to welders for operations witnessed and a comparison against require-ments of the applicable welding procedure specifications.
e.'
Examination of components identified in c. above relative to fabrication status denoted by applicable Quality Control.and Assurance Data Sheets.
f.
Examination. of Welding Engineering surveillance records for production welding operations.
g.
Review of fabrication records for three (3) recent y com-pleted assemblies.
3.
Findings a.
Deviation from Commitment See Enclosure, Item D.
b.
Unresolved Items None.
D.
Elevated Temperature Heat Treatment 1.
Objectives The objectives of this arou of the inspection were to verify that elevated temperature heat treatment was performed in accordance with written procedures and that the procedures were consistent with applicable NRC and material specification requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 9 Revision 3, " Control of Special Processes."
b.
Review of audit report for approved vendor utilized for solution annealing of austenitic stainless steels.
c.
Examination of heat treatment records for Job No. 3002, Sketch 7.
. d.
Review of applicable customer solution annealing require-ments.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
E.
Exit Meeting A post inspection meeting was held on April 13, 1978, with the management representative denoted in paragraph A. above.
The inspectors summarized the scope and findings of the inspection.
Management was also advised that a recommendation would be made, as a result of the continuing failure of Dravo to fulfill QA program commitments, for referral of the inspection findings to IE Head-quarters for determination of required enforcement accions, tianagement comments were related to both clarification of the findings and a discussion of the monthly meetings, which had been instituted in November,1977, for the purpose of strengthening awareness and implementation of QA program requirements.
. DETAILS SECTION II
(. Prepared by H. W. Roberds)
A.
Persons Contacted R. L. Anderson, QA Supervisor J. Moore, Chief Inspector D. S. Gilchrist, QA Engineer R. Kemp, Welding Foreman D. L. Walker, NDE Level II R. L. Davis, Welding Engineer B.
Action on Previous Inspection Findings 1.
(Closed) Deviation II.C.3.a.(1) (Report No. 77-02):
It was verified that a check of documentation was being made prior to final inspection to assure that the specific weld material and weld operator identification number was entered in the appropriate box on the sketch.
The inspector ascertained, however, that all corrective actions had not been completed as committed. (See Enclosure, Item E).
2.
(Closed) Deviation II.C.3.a.(2) (Report No. 77-02):
It was verified that Weld Engineering had made provisions for checking the entry of the weldors stamp number on the weld joint data form.
3.
(Closed) Deviation II.C.3.a.(3) (Report No. 77-02):
It was verified that a review of the weld procedures had been made prior to January 27, 1978.
4.
(Closed) Deviation II.C.3.a.(4) (Report No. 77-02):
It was verified that nondestructive examination procedures and revisions were recorded on specific back-up shop documents.
The inspector ascertained, however, that all corrective actions had not been completed as committed (See Enclosure Item F).
5.
(Closed) Deviation II.C.3.a.(5) (Report No. 77-02):
It was verified that a procedure had been written that delinated applicaole records to be accummulated for review by the ANI prior to execution of the code data report.
4
- s The inspector ascertained, however, that all corrective actions had not.been implemented as committed (See Enclosure Item G)..
i
.6.
(0 pen)DeviationII.C.3.a.(6)(ReportNo.-77-02): Written instructions had not been formalized or issued to production relative to ANI Hold Points to assure compliance with Section 10 of the QA Manual requirements.
C.
Nondestructive Examination (Dye Penetrant) i 1.
Objectives
)
.The objectives of. this area of the inspection were to verify that:
a.
Nondestructive examination is performed.1n accordance with approved procedures.
b.
Nondestructive examination procedures meet the require--
ments of Section V of the ASME Code.-
c.
Test results are interpreted by qualified personnel.
2.
Method of Accomplishment The ~ preceding objectives were accomplished by:
a.
Review of section 9 of the QA Manual.
b.
Review of Liquid Penetrant' Inspection Procedure ASME-III DP.
Review of NDE Training and Certification Program for c.
level I and II.
d.
Observation of work in progress.
e.
Interviews with cognizant personnel.
3.
Findings a.
Deviations (1) See Enclosure Item H.
(2) See Enclosure Item I.
i 6
I
. b.
Unresolved Items None.
c.
General Comment Due to work not being performed on code related items in the methods of UT, MT and RT these methods are deferred until the next scheduled inspection.
D.
Material Control 1.
Objectives The objectives of this area of the inspection were to verify that procedures and instructions have been established to implement a system for material control and identification in accordance with applicable regulatory, code and contract requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 7 and 8 of the QA Manual.
b.
Verification of material identification from the component to the material records.
c.
Selective review of records of purchased materials.
d.
Interviews with cognizant personnel.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
. i DETAILS SECTION III (Prepared by P. I. Verrios)
A.
Persons Contacted J. Moore, Chief Inspector D. Berrows, Recieving Supervisor C. Wilhelm, QA Technician D. Gilchrist, QA Engineer L. Stiles, Project Engineer G. Sears, Foreman Shop #2 E. Stilgembayer, Production Manager A. Hiemer, Squad Leader L. Dean, Project Supervisor.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation No. III.D.3.a (Report No. 77-02): The inspector verified that Dravo has implemented the committed corrective action relative to vendor audits.
The inspector determined that the committed steps to preclude recurrence had not been implemented.
(See Enclosure, Item J).
2.
(Closed) Deviation No. III.E.3.a.(1) (Report No. 77-02): The inspector verified that Dravo has implemented the committed corrective action.
C.
Internal Audits 1.
Objectives The purpose of this inspection was to verify that:
a.
Procedures or policy documents clearly identify organi-zations responsible for audits and define their respon-sibilities and authorities.
b.
Measures have been established to assure that auditors are independent of any direct responsibility for performance of activities which they are auditing and that persons having direct responsibility for performance of the activities being audited are not involved in the selection of the audit team, i
t c
, c.
All_ auditing ~ personnel, including technical specialists, are required,to recieve appropriate training or orienta-tion to develop their competence for performing required audits.
d.
- Guidelines 'and requirements are established for audit scheduling and. that they.take. into consideration the.
status and importance of. the activities to be audited.
- e..
Sufficient instructions or guidance are available to'the
' auditors in the form of checklists or procedures to perform the audits effectively and in accordance with the audit. plan, f.
Deficiencies it'entified by the audits are closed out by appropriate corrective action and timely follow-up, including reaudit of deficient areas.
g.
Audit records are collected, stored and maintained in accordance with applicable code and contract require-ments.
- 2..
Method of Accomplishment.
The preceding objectives were accomplished by:
a.
Review of Section 17 of the QA Manual, Revision 3.
b.
Review of the following internal audits:
Audit of Engineering Department.
Audit of Quality Assurance.
Audit of Inspection Department.
. Audit of Purchasing Department.
Audit of Weld Engineering and Production Welding.
c.
Interviews with cognizant personnel.
3.
Findings
-a.
Deviation (1) See Enclosure, Item K.
(2) Sen Enclosure, Item L.
b.
Unresolved Items i
None.
9
=
. 2
=
i
, i c
D.
Procurement' Control (Vendor Audits) 1.
Objectives t
The purpose of this inspection was to. verify that:
1 a.
Written procedures for.this activity are available and in use.-
b.
Evaluations were performed prior to award of contracts and at tiie specified frequency.
}
c.
Sufficient instructions or guidance is available to the auditors in the form of checklists or procedures to perform the audits effectively and in accordance with the audit plan.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 7 of the QA Manual revisions 2 and 3.
I b.
Review of Section 17 of the QA Manual Revision 3.
c.
Review of the Qualified Vendor List dated March 24, 1977.
d.
Review of twenty-five (25) randomly selected Appro' ed Vendor files.
e.
Interviews with cognizant personnel.
l 3.
Findings L
i a.
Deviations None.
b.
Upresolved Items a
Cr terion VII of Appendix B to 10 CFR 50 states in part,
"... The effectiveness of the control of. quality by contractors and subcontractors shall be assessed by the ' applicant' or designee at intervals consistent with t
the importance, complexity, and quantity of the product or services."
4
.5
. Section 17 of the Quality Assurance Manual Revision 3, paragraph 4.1 states, "When required, the quality assurance manual, procedures, operations, facilities, etc. of Dravo vendors shall be audited to assure that they comply with the ASME III Code, the applicable regulatory requirements and other applicable standards that may be invoked by customer requirements." Also same section paragraph 4.5 states, "When a vendor has a valid ASME Certificate issued by the Society, Dravo may, at its option waive the requirement for an in-plant audit of the vendor.
Based on the subjective wording of Dravo Quality Assurance Manual the area of external audits is not auditable.
E.
Design and Document Control 1.
Objectives The objectives of this area of the inspection were to:
Verify that the overall designs, including calculations, a.
material selection, stress analysis reports, are reviewed for compliance with the design specification and code requirements.
b.
Verify that the reviews and checking of the design docu-ments are performed by qualified personnel other than those responsible for the original.
Verify that revisions, changes, and/or addenda to design c.
documents are reviewed in the same ma.aner as the original, d.
Verify that the reviews and checks of design documents are appropriately documented in a.nanner that is auditable.
Verify that procedures are implemented for the review, approval, e.
release and distributica of design documents including changes thereto, by participating design organizations.
f.
Verify that mea.3ures established require that any i
deviations from the design document identified by in-process or final inspections, be reported to the respon-sible design organization for review, evaluation and appropriate disposition,
2.
Method of Accomplishment The preceding objectives were accomplishcd by:
a.
Review of the QA Manual, Section 3, revision 3.
b.
Reveiw of Specification 10855-P-201 (Q).
c.
Review of specification 10855-G-001.
d.
Review of fifty-five (55) randomly selected sketches.
Interviews with Engineering and shop personnel.
e.
3.
Findings a.
Deviations (1) See Enclosure, Item M.
(2) See Enclosure, Item N.
b.
Unresolvec Items None.
F.
flonconforming Materials, Parts or Components 1.
Objectives The purpose of this inspection was to verify that:
A system has been established for identifying and reporting a.
nonconformances.
b.
The system for nonconformance identification contains, as a minimum, the following elements:
(1)
Identification of item.
(2) Description of nonconformance.
(3) Segregation of the item, as appropriate.
(4) Signature of the reporting party.
J
~
. The assigaed responsibilities are carried out by the c.
designated persons.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the QA Manual, Section 14, Revision 3.
b.
Review of the QA lianuel, Section 8, Revision 3.
Peview of twenty-five (25) randomly selected CMTR'S c.
d.
Review of fif ty (50) randomly selected NCR's.
e.
Observation of designated segregation and hold areas.
f.
Interviews with cognizant personnel.
3.
Findings a.
Deviations (1) See Enclosure. Item 0.
(2) See Enclosure, Item P.
b.
Unresolved Items None.
G.
Equipment Calibration 1.
Objectives The purpose of this inspection was to verify that:
a.
A system has been established and is maintained to assure that tools, gages, instruments and other measuring devices.used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within specified limits.
b.
Calibration records are kept for each instrument and that these records include the following information:
4 i
i (1)
Purchase date and calibration history.
I (2) Accuracy required and calibration results.
(3)
Location for use.
(4)
Present calibration interval and date due.
(5) All maintenance and repair details.
(6) Persons or agency performing all calibration.
(7) Serial number or identification of each standard used to perform the calibration.
l (8) Number or name of the calibration procedure.
(9)
Environmental conditions used during calibration.
(10)
Equipment recall schedules.
2.
Method of Accomplishment i
The preceding objectives were accomplished by:
a.
Review of the QA Manual Section 17., Revision 3.
b.
Review of Standard Procedure No.107, Revision 3.
Verification of calibration status of twenty-five (25) c.
randomly selected outside Micrometers, Calipers, master blocks, depth micrometers, and inside micrometers.
3.
Findings a.
Deviations See Enclosure, Item Q.
b.
Unresolved Items None.
7..
DETAILS SECTION IV (Prepared by D. M. Hunnicutt)
Management Meeting 4
A meeting was held in the NRC Offices, Bethesda, Maryland, on May 8,1978, at the request of NRC to discuss Dravo Corporation's (Dravo) history of failure to meet.NRC requirements, their responses to identified ' deviations, and their failure to fully. implement their Quality Assurance Program.
Those in attendance were:
DRAVO Mr.'G. Schwab, Vice President and General Manager Mr. R. L. Anderson, QA Supervisor Mr. W. A. Molvie, QA Manager and Chief Engineer NRC Mr. N. C. Mosley, Director, RCI Mr. G. W. Reinmuth, Assistant Director, RCI Mr. K. V. Seyfrit, Assistant Director, ROI Mr. U. Potapovs, Section Leader, Materials Integrity Section, NRR Mr. D. M. Hunnicutt.,-Acting Chief,.VID Mr. Moseley stated that Dravo had failed to take necessary corrective actions to alleviate problem areas and had failed to fully implement their Quality Assurance Program, as demonstrated by the results of the.last four inspec-.
tions covering a two year period.
Mr. Moseley stated that the findings included lack of corrective actions on identified deviations, failure to meet commitments made by Dravo management, and repeat deviations in the-same areas as previously identified deviations.
Mr. Schwab stated that Dravo management was aware of the identified problems.
He said that several of the problems were related to major contracts that had t
1 been in effect since the early 1970's.
Mr. Schwab stated that the production staff was oriented towards the production of acceptable hardware and the specific job requirements, but had not carried through on the documentation of work related to the hardware fabrication. Mr. Schwab stated that signif-icant progress has been made towards refining procedures and improving internal audits.
He also reported the assignment of a welding engineer, who' will check
-the welding machine setup and welder adherence to procedures.
Mr. Moseley stated that NRC expected to see the Dravo Quality Assurance Program, including auditing, identify and correct problems. prior to NRC identification of these deficiencies.
f I
...o
. Mr. Anderson stated that the Quality Assurance staff has increased in size, has an internal audit program, and that the general Quality Assurance attitude has shown improvement.
Mr. Anderson stated that the internal audit program should be fully effective by early July.
Mr. Schwab stated that the ASME had been contacted and that the ASME would serve as an additional source of audit and would participate in corrective action follow-up at Dravo.
Mr. Schwab stated that Dravo will establish a plan to complete corrective actions related to previously identified NRC deviations and items identified by Dravo during their internal audits.
NRC stated that the program outlined by Dravo appeared to have the elements necessary to achieve correction of identified problems, if properly implemented.
Dravo was also told that NRC inspections would be scheduled in the near future to determine the effectiveness of the Dravo program.
.