ML20150C081
| ML20150C081 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20150C063 | List: |
| References | |
| REF-QA-99900081 NUDOCS 7811100084 | |
| Download: ML20150C081 (3) | |
Text
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O Exxon Nuclear Company, Inc.
Docket No.
99900081/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on August 28-31, 1978, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated belcw:
A.
Criterion IX of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accom-plished by qualified personnel usinq qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Exxon procedure XN-10, 7.48, Liquid Penetrant Inspection Dip Tank Method Fluorescent Penetrant, Revision 1, Section 1.0, states in part, "This procedure is in accordance with ASTM E 165."
Exxon Product Specifications (eg. XN-S30073) require penetrant inspection to be in accordance with ASTM E 165-65.
Contrary to the above, the penetrant procedure was not in accordance with ASTM E 165. The development time used for the Spot Check developer was 2 minutes not 15 as required and the dwell time of the Doublecheck penetrant was 15 minutes not 30 as required by ASTM E 165-65 (See DetailsSection I, C.3).
B.
Criterion V of Appendix B to 10 CFR 50 states, " Activities affecting quality shal'l 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.... "
Exxon procedure XN-64, 2.1, Certification of QC Inspection Technicians, Revision 0, Section 8.0, states in part, "All files shall contain the following information as a minimum:
a.
Past performance history b.
Contrary to the above, files did not contain the past performance history of the nondestructive examination technicians. This past performance history is used as the basis of requalification of technicians.
(See DetailsSection I, C.3.)
781110 00fr'i
-- C.
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 I
are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."
Exxon Quality Assurance Program, XN-NF-1, Revision 1, Section 12, states, " Procedures are established for the control of measurement and test equipment used in the development of processes and in the fabrication and inspection of fuel and fuel components which can directly affect product quality.
Measurement and test equipment are those devices used to measure product characteristics, or to monitor process perfonnance for items where subsequent inspection is not performed.
Examples of such equipment irclude inspection gages, scales and balances and NDT standards."
Contrary 'co the above, two Bethehem torsion balances were found in the Emission Spectrographic Lab which were not addressed in procedures for the control of measurement and test equipment.
These balances are used for spectrochemical determination of impurities in fuel and also indirectly for the uranium analysis.
(See DetailsSection I, D.3.)
D.
Criterion V of Appendix B to 10 CFR 50, states in part that, " Activities affecting quality shall be prescribed by documented instructions, precedures or drawings."
Exxon Quality Assurance Program, XN-NF-1, Revision 1, Appendix II, commits to the applicability of ANSI N45.2.9 ANSI N45.2.9, paragraph 5.3, and QA Procedure No. 17,.naragraph 4.7, require pre-paration of a storage procedure which includes a description of the storage area (safeguards viewpoint) and a method for verifying that records received are in good condition.
Contrary to the above, Document Control Standard Operating Procedures, XN-NF-365, implementing proctJures governing QA record receipt and storage in the central vault do not describe the storage area or indicate the method of verifying acceptable condition of records received.
(See DetailsSection II, B.3.)
E.
Criterion XVI of Appendix B to 10 CFR 50, states in part, "In the case of significant conditions adterse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
I
- Exxon Quality Procedure, Deviating Material Control System, No.15, states in part, " Preventative action is recommended by checking the appropriate block on the DMR (Deviating Material Report) form and completing the recommended preventative action section of the Preventative Action page of the DMR.
The Supervisor or Manager signs
... concurring.
' ne Manager of Quality Control shall maintain follow-up status."
Contrary to the above, although DMR-AA 07578 is checked, " Preventative Action Required," the required Preventative Action Form for correction of rod spacing on a recent project was not generated, attached, approved and distributed, and follow-up status was not tracked.
(See DetailsSection II, D.3.)